More EU restrictions of hazardous chemicals

ECHA has a Registry of Restriction Intentions. It contains a long list of various chemicals proposed for restrictions by ECHA or member countries. The two most recent proposals for restrictions of hazardous chemicals were submitted on 5 October 2018.

  • ECHA proposed restricting of the placing on the market of the 5 “soluble” and carcinogenic cobalt(II) salts for professional and industrial use. These salts are: cobalt carbonate (insoluble in water!), cobalt di(acetate), cobalt dichloride, cobalt dinitrate and cobalt sulfate. The restriction proposal seeks to decrease the individual excess cancer risk levels and resulting number of cancer cases arising from occupational exposure to these salts through inhalation. It requires registrants and downstream users to implement a reference exposure value of 0.01 µg/m3 in their chemical safety assessments. ECHA considers this the most appropriate Union-wide measure to ensure a high level of protection of workers reducing the risk of cancer linked to exposure to cobalt salts. Comment: Because the focus is on inhalation of carcinogenic cobalt in occupational settings, it is surprising for me that other cobalt salts and cobalt metal dust are not included. Better had been to use “cobalt and its compounds” as used for other toxic metals listed below.
  • Italy proposed restricting of the placing on the market of the important but reprotoxic solvent: N,N-dimethylformamide (DMF) on its own and in mixtures in a concentration of ≥ 0.3 % for the risk reduction for the general worker population to use in their chemical safety assessment and safety data sheets a harmonised long-term derived no-effect level (DNEL) value of 3.2 mg/m3 for inhalation and of 0.79 mg/kg bw/day for dermal exposure. Comment: This substance is also included in the actual restrictions for use in textile products as discussed below and with the same concentration limit (0.3 % = 3000 mg/kg).

On Wednesday 10 October 2018, the European Commission adopted new restrictions for 33 hazardous substances (CMR substances) for their use in new clothing, footwear and other textile products. It will be illegal to place such products on the market, if the materials contain more of these substances than the maximum concentration limit. The restrictions will apply to companies from October 2020 onwards. There are, however, a few exemptions. More (ECHA Weekly, 17 October 2018).

Table with the 33 restricted “substances” (single substances or chemical groups) amending REACH Annex XVII and their maximum concentration limits by weight in homogeneous materials:

Comment: This table is somewhat shortened and modified. The original substance table in the draft regulation has, as usual for EU, many spelling errors, and the nomenclature system used is disputable and inconsequence. If juridical and economical terms were handled by EU in the same way as chemical names, it had been a big scandal!

Other comments:

Cadmium and its compounds are already restricted for use in plastic materials and paints.

There is already a general restriction in force of use of chromium(VI) in cement and leather articles with a maximum concentration of 3 mg/kg, thus 3 fold higher than the new limit for textiles in the table. In 2012 Denmark proposed restriction of leather articles containing chromium(VI). It is unclear, if leather in general is covered by the new restriction of chromium(VI) in textiles and footwear.

Arsenic compounds are already restricted in e.g. wood preservatives.

There is already a general restriction in force of use of lead and lead compounds in jewellery.

Benzene is already restricted in e.g. toys.

There is already a general restriction in force for use of polycyclic aromatic hydrocarbons (PAH) in tyres with a limit value of 10 mg/kg of the same 8 listed hazardous PAH components and 1 mg/kg specifically for benzo[a]pyrene.

N-Methyl-2-pyrrolidone (NMP) in the table has already another specific restriction from May 2020 concerning workers exposure. Manufacturers, importers and downstream users have to include in the relevant chemical safety reports and safety data sheets, a Derived No-Effect Levels (DNELs) relating to exposure of workers of 14.4 mg/m3 for exposure by inhalation and 4.8 mg/kg/day for dermal exposure.

2-Naphthylamine and its salts, including 2-naphthylammonium acetate in the table, are already generally restricted in a higher concentration and “shall not be placed on the market, or used, as substances or in mixtures in concentrations greater than 0.1 % by weight.”

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