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Environmental Resources Management

ERM

Independent technical support and sustainability services, working with a range of industry stakeholders.

Lobbying Activity

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

15 Jan 2021 · Chemicals

Meeting with Deirdre O’Hea (Cabinet of Commissioner Mairead Mcguinness)

13 Jan 2021 · EU regulatory framework for authorisation of substances

Response to Commission Regulation amending Annex XIV to REACH

9 May 2019

INPUT OF THE ADCA TASK FORCE On behalf of the ADCA Task Force, we would like to highlight our concerns regarding the inclusion of ADCA in the proposal to amend Annex XIV of Regulation 1907/2006. The ADCA Task Force represents over 40 companies involved in the marketing and use of ADCA (Diazene-1,2-dicarboxamide (C,C'-azodi(formamide)), CAS Number: 123-77-3). We would express our objections to the suggestion to list ADCA in Annex XIV, given the substantial impact that such legislative change would have. ADCA has many important uses and its listing on Annex XIV of REACH would have a negative impact on many of the Commission’s identified priorities including for the circular economy, energy efficiency and reduction of CO2 emissions, for employment and on the competitiveness of industry, in particular SMEs. Annex XIV listing for ADCA is disproportionate and not a suitable option. It is our strong view that ADCA should not be listed as an SVHC as it cannot be considered to meet the criteria of provoking ‘equivalent concerns’ to those elicited by CMRs. With new data available, this justifies evaluation and a review of the initial ECHA recommendation. With all uses of ADCA being at an industrial level, alternative policy measures should be considered to boost ongoing efforts to minimize workplace exposure. The setting of an OEL in the UK in 1996 has led to a situation where there are practically no reported occupational health cases related to ADCA. The ADCA Task Force therefore call for: • The European Commission and the Reach Committee to exclude ADCA from the proposed list of substances for inclusion in Annex XIV of REACH • The European Commission to put in place the necessary steps to establish suitable alternative measures to further ensure that worker exposure is minimized and controlled at an European level. Important uses of ADCA ADCA is a key blowing agent used in a number of sectors including construction (thermal insulation, flooring & plastisols, pipes, foamed profiles), automotive (trims, coated fabrics, sealing gaskets, noise and vibration reduction), aerospace (thermal insulation) and consumer products (sports & leisure, household & packaging). Once used and processed, ADCA reacts and decomposes in the production of plastic and rubber end products. Benefits of ADCA ADCA is a particularly important input in the production of energy efficient applications, including in the automotive and construction sectors. ADCA has a role in supporting the Commission’s aims on energy efficiency and emission reduction – while at the same time contributing to passenger safety and comfort. Alternatives to ADCA Much research has been carried out by the industry to identify suitable alternatives. However, from a recent analysis by downstream users, it was concluded that there are no other alternative substances that can be used in the manufacture of foamed plastics and rubber articles currently using ADCA since they are less performant and furthermore of higher concern in terms of health and safety properties (e.g. OBSH). Impact of Annex XIV listing The analysis also highlighted the economic impact of listing ADCA on Annex XIV. The authorisation scenario would lead to revenue and job losses for the plastics and rubber supply chain as a whole, with an estimated revenue loss of €1.8 – 2.7 billion and between 6,000 – 8,000 job losses. The effects identified would mainly be through companies delocalizing activities, with new investments and updates of equipment being focussed outside the EU. The potential listing of ADCA on Annex XIV would have a disproportionate impact on many SMEs. Attachments: We enclose as an attachment a joint statement from number of organisations including the ADCA Task Force. The attachment includes • Multi-association letter and communication on Annex XIV proposal • Summary Report on ADCA uses in plastics and rubber sectors and impact of potential inclusion in Annex XIV.
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

14 Jan 2019 · Listing of ADCA in Annex XIV of Reach

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and European Tyre & Rubber Manufacturers' Association and European Plastics Converters Association

14 Jan 2019 · listing of ADCA in Annex XIV of REACH

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

14 Jan 2019 · Listing ADCA