European Biocidal Silver Task Force
EUSTF
The European Biocidal Silver Task Force is made of 13 companies supporting various silver containing active substances in the review programme of active substances under the Biocidal Products Regulation (EU) No 528/2012 - BPR.
ID: 087556034207-96
Lobbying Activity
Response to Revision of lists of pollutants affecting surface and groundwaters
13 Mar 2023
The European Biocidal Silver Task Force (the EU STF) takes note of the Commission's proposal to include silver in the Water Framework Directive (WFD)'s list of priority substances. The EU STF considers that: (a) the significant costs associated with including silver in the list will far outweigh its benefits, rendering the proposal disproportionate; and (b) the proposal is unscientific and contains critical errors. The EU STF is particularly concerned by the Impact Assessment's manifestly unsound conclusion that the high costs associated with including silver can be justified due to an alleged benefit from the prevention of antimicrobial resistance (AMR). Including silver in the priority substance list, without having demonstrated a serious risk, means major costs will be incurred without bringing any real benefit to the aquatic environment or the health of EU citizens. This is disproportionate and an unjustifiable use of resources. The EU STF recommends that silver's inclusion in the priority substance list (Annex I of the EQS Directive) is omitted from the proposed amendments to the WFD and EQS Directive. Instead, a more proportionate and practical step would be to provide for the monitoring of any development of microbial genes resistant to silver in the next Watch list (the possibility of which is now provided for under Article 8b of the proposed EQS Directive). Please find our detailed comments and a supporting appendix attached. About the EU STF: The European Biocidal Silver Task Force was created in 2006 to support the continued use of silver and silver substances as antimicrobials in the European Union. It is made of the 13 companies supporting various silver containing active substances in the EU's biocide review programme.
Read full response19 Nov 2021
The European Silver Task Force (EUSTF) welcomes this opportunity to provide comments on the Commission's proposed update to the list of combinations included in Annex II, Commission Delegated Regulation (EU) No 1062/2014 (the Review Regulation).
The EUSTF is a collection of 14 member companies supporting various silver containing active substances in the EU biocide review programme. These substances include silver, silver nitrate, silver chloride, silver-polyethylenimine-chloride, silver sodium hydrogen zirconium phosphate, silver zeolite, silver phosphate glass, silver borophosphate glass, silver phosphoborate glass, silver zinc zeolite, silver copper zeolite and silver adsorbed on silicon dioxide (as a nanomaterial in the form of a stable aggregate with primary particles in the nanoscale).
On behalf of the EUSTF, we confirm that the proposed list of combinations for silver containing active substances aligns with the understanding of our members, save for some minor points below.
1. Reaction mass of titanium dioxide and silver chloride (entry number 459)
ECHA has published open invitations for notification for all active substance / PT combinations referred to in the proposed list.
• The deadline for notification in respect of PTs 1, 2, 6, 7 and 9 expired on 18 August 2021. We are not aware that these PT combinations have been taken over and in consequence they are out of the review programme. We therefore expect these PT combinations to be excluded from the list included in the draft Annex to the Delegated Regulation.
• The above does not apply in respect of PTs 10 and 11 as the deadline to take over these PTs is 30 June 2022.
2. Silver chloride (entry number 1016)
One of our member companies notified ECHA and KemI in June 2021 that it was withdrawing its support for this substance in PT 1. As per Article 14(1)(a) of the Review Regulation, ECHA is not required to publish an open invitation for notification in respect of this combination because it was previously taken over, having been listed in part 2, Annex II of the Review Regulation. We therefore expect this PT combination to be excluded from the list included in the draft Annex to the Delegated Regulation.
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We hope you find the above information useful. If you have any further questions, please contact us directly and we would be happy to assist.
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