Eurocolour e. V.
Eurocolour
Zweck des Verbandes Eurocolour e.V.
ID: 902192634607-21
Lobbying Activity
Response to Persistent organic pollutants - Polychlorinated biphenyls (PCB)
13 Mar 2025
We appreciate the Commissions and Member States approach to adapt the Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs) regarding the introduction of a UTC limit for Polychlorinated biphenyls (PCBs). We support the Draft Delegated Regulation with regards to the approach for organic pigments. In our view, setting a UTC limit value of 10 ppm for the sum of 209 different PCB congeners is challenging, but achievable. This is essential to maintain the manufacture of organic pigments and downstream production chains in Europe, enabling an effective influence and control over the PCB contents in products. European pigment manufacturers have been striving for years to reduce PCB values through process optimization, and they will continue their efforts. However, complete elimination in some cases is not possible due to undesired competitive chemical reactions. Chlorinated organic pigments cannot be easily substituted due to their properties, their performance and their relevance for downstream user applications. Therefore, in-depth knowledge of the production processes and their optimisation is required to obtain low PCB contents. An achievable limit value of 10 ppm will enable this knowledge to be sustained in the EU. Since European downstream manufacturers also depend on imports of pigment feedstocks from outside the EU, we strongly recommend having a sufficient transition time to allow non-EU manufacturers to become aware of and adapt to the European requirements. By setting a limit value of 10 ppm, the EU would introduce the lowest value worldwide and could play an active role in reducing the total amount of PCBs produced and imported. Any unworkable lower limit value would have severe impact on the organic pigment industry and corresponding downstream user. Furthermore, there are limiting analytical challenges that, to our knowledge, still remain with substances which are soluble in organic solvents. We welcome the introduction of ISO 787-28:2019, which is developed specifically for organic pigments, as test method to enable enforcement, compliance, and to create a level playing field. Given that this method, which involves the total dissolution of organic pigments, is not widely used among non-EU manufacturers, it will take some time for them to adapt to it. For both of these reasons, having a transition period of at least 3 years from entry into force to reach the 10 ppm limit value is highly necessary to avoid disruptive effects on the supply chains. Eurocolour e. V. is the umbrella association for manufacturers of pigments, dyes, fillers, frits, ceramic and glass colours, and ceramic glazes in Europe.
Read full response10 Apr 2024
Please note our detailed statement, which we have uploaded with this entry. Our key messages: Contradiction summery and draft regulation ! New rules of high degree purity for substances made from waste and natural materials, as announced since 2022 and communicated in 2023, not unexpectedly extended to all substances ! No purity requirements with migration limits that are not feasible in practice (0.15 ppb and 50 ppb). Requirements that lead to a purity level for raw materials of >99.99999 % do not make sense in practice. New rules for a high degree of purity are not required for colorants and fillers. Studies have shown that there is no migration from the inside of a plastic matrix. Conclusion: We reject the new limits. Purity requirements that go beyond the requirements of Regulations (EU) No. 1333/2008 and (EU) No. 1334/2008 for food additives are not feasible in practice. We propose pragmatic approaches for colorants, such as upper limits for PAA, PAH and metals. The rules for purity are incorrectly positioned in (EU) No 10/2011, these rules should be included in the Framework Regulation for FCM (EU) No 1935/2004 or in regulation (EU) No 2023/2006 good manufacturing praxis.
Read full response27 Mar 2024
Eurocolour welcomes the establishment of a common data platform to support sound scientific hazard and risk assessments. But there are still some areas of concern in the draft which we would like to elaborate on: Make best use of industries expertise: The establishment of the common data platform will be a complex and time-consuming task. To lessen the burden of the Regulators and to ensure that the platform will be finished in the proposed timeline industry experts should be consulted. With this the workload on the Regulators would be reduced and expertise of the industry used. With this the goals of the common data platform could be achieved in the short timeline. Data generation mechanisms: The possibility to request new data, provided to ECHA, could lead to unnecessary studies which are not relevant for existing EU law. Therefore, we believe this mechanism should not bypass existing specific data generation provisions. Here a cross-check with industry could be beneficial. Stakeholders could be consulted on a draft testing proposal, including a reason why such testing is necessary. Study notification: Clarify and design a fit-for-purpose scope: We worry that the introduced additional notifications could lead to problems concerning confidentiality, in addition to the administrative burden that may result of the introduction. We are concerned about the fact that risk assessment tests that are not mandatory under any regulation may have to be notified, as this could contain confidential information, not in terms of the tests themselves, but in regard to the substances or products on which they have been carried out. Should testing for research and product development purposes which could later-on be decided to be used for regulatory purpose also be notified? Would a subsequent notification be deemed required? Grouping of substances: We support the grouping of substances to reduce the burden on regulators as well as the industry if grouping is based on scientific data. We fear that even though data is available in the newly formed system, substances will still be grouped on structural similarities and not based on toxicological data. This could lead to incorrect grouping of individual substances and therefore over or wrong classification of some substances. A wrong classification is not only harmful for business or competitiveness but can in some cases but dangerous for human health or the environment. This is especially worrisome as the scientific data, on which this grouping will be taking place, is not defined.
Read full responseResponse to Revision of the definition of engineered nanomaterial in food
12 Jan 2024
Eurocolour, the umbrella association for manufacturers of pigments, dyes, fillers, frits, ceramic and glass colours, and ceramic glazes in Europe, thanks the European Commission for the opportunity to comment on the draft Delegated Regulation amending Regulation (EU) 2015/2283 as regards the definition of engineered nanomaterials. We welcome the harmonisation with the Commissions Recommendation of 10 June 2022 on the definition of nanomaterial and the clarification that all manufactured materials, regardless of how and from which starting materials they are produced, would fall under the definition if the particle size distribution contains 50% or more particles with less than 100 nm. As stated in Article 2 of Regulation (EU) 2015/2283, the Novel Food Regulation does not apply to food additives covered by Regulation (EC) No 1333/2008. Therefore, we assume that the definition of nanomaterials is related to novel food. The Regulation (EU) No 1169/2011 on the provision of food information to consumers refers to the definition of engineered nanomaterial in the Novel Food Regulation. The cross-reference only to sub-paragraph (f) of Article 3(2) of Regulation (EU) 2015/2283 removes the definition from the original "purposes of this Regulation" under which it is listed in this article. We would like to recall that the definition of a nanomaterial based on the size was explicitly established without any reference to a potential hazard or change in function or properties. The Regulation (EU) No 1169/2011 on the provision of food information to consumers would require all ingredients and additives falling under the definition of engineered nanomaterial to be labelled with "(nano), even if they are not covered by the Novel Food Regulation. In practice, this would lead to an avoidance and removal of well-tested and approved additives, although there is no hazard related rationale and need to do so. This issue is not addressed in the current draft. As long as there is no amendment of the Food Information Regulation in sight, we suggest as a workaround to include in the definition the relevant limitation to the novel properties addressed in the Novel Food Regulation: 'Engineered nanomaterial' means an intentionally manufactured material in the nano-size range to fulfil a new specific purpose or to deliver a new specific function, differentiating it from forms of the same material being on market within the Union before 15 May 1997 and which consists of solid particles that are present [...] Thank you for your consideration of this contribution. We remain at your disposal for further discussion.
Read full response25 Jun 2019
Eurocolour welcomes the possibility to comment on the „Inception Impact Assessment on migration limits for lead, cadmium, and possibly other metals from ceramic and vitreous food contact materials”.
With regard to the proposed Roadmap we would like to submit the following comments which are highly important and should be taken into consideration by the European Commission.
The plan for lowering the limit for lead and cadmium and the introduction of new limits has huge consequences for the use of ceramic colours and ceramic frits, and, in particular, onglaze colours and the whole glazes sector.
Ceramic colours must have special properties for their use and fixing on tableware. One important property is temperature stability. Therefore, unlike in other fields of application (e.g. coatings or plastics), frequently adequate alternatives are not available. The proposed limit values for lead and cadmium would significantly reduce the diversity of colours, with the colour ranges red-orange, intense yellow and green shades being particularly affected.
Moreover, should the limit values for cobalt be prescribed in a regulation as currently under discussion, there is also the danger of losing almost all shades of blue.
We estimate that over 50% of ceramic colours would no longer remain on the market.
Ceramic decoration mostly relies on the onglaze technique. A significant lowering of the limits, as discussed by the European Commission, would mean the end of the onglaze technique in Europe and therefore a significant damage for the tableware production in Europe.
All this would result in an obvious competitive disadvantage for European manufacturers compared to competitors from outside Europe.
As stated in the Roadmap, the general objectives of the initiative are to protect human health and to contribute to the smooth functioning of the single market.
For more detailed comments, we would initially point out that for our industry, too, consumer protection and human health are the highest priorities.
Lowering limits for lead and cadmium or introducing new limits for the other mentioned heavy metals will result in very complex and cost intensive test methods for the manufacturers of the food contact materials.
In the planned initiative for lowering limits for cadmium and lead and the introduction of new limits, the identification of the relevant test methods is a key element: Future limit values and the test methods should both serve consumer protection and remain workable and in line with the principle of proportionality. This means that the test methods must be assessed with regard to their relevance in practice.
In consequence, the test methods for the migration limits of the mentioned metals must clearly distinguish between hollow ware (e.g. vessels, bowls or jars) and flatware (e.g. plates). For example, the EU Commission’s current assumptions for an exposure scenario, the proposed limit values and the test method are totally unsuitable for flatware (e.g. plates).
Finally, a short remark on the mentioned basis in the Roadmap:
We basically agree to the Europe-wide approach for migration limits to prevent further uncoordinated national initiatives and replace existing ones, as these have negative impacts on the European market.
About Eurocolour:
Eurocolour e. V. is the umbrella association for the manufacturer of pigments, dyes, fillers, frits, ceramic and glass colours and ceramic glazes in Europe, www.eurocolour.org
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