EUROPEAN COIL COATING ASSOCIATION
ECCA
ECCA is an International Non-Profit Association, dedicated to the promotion of the use of prepainted metal as the environmentally sound, the cost effective and the high quality method of finishing.
ID: 8427163134-48
Lobbying Activity
Response to EU rules on industrial emissions - revision
16 Apr 2020
The proposed objectives and policy options (section B) can be clearly divided into two main areas:
(a) Fixing issues that have been identified with the current process e.g. improvement to the BREF process, addressing areas of weakness, coherence with other EU legislation.
(b) Broadening the scope of the IED e.g. new sectors, circular economy, decarbonisation.
Both objectives require a considerable amount of work on their own; the proposal to cover both areas at once seems overly ambitious and may result in a lack of focus on some of the topics. It may be more appropriate to adopt a more sequential approach whereby the issues with the current process are addressed first, followed by the broadening of the scope.
The statement “ There are not expected to be large economic impacts” (section C) severely under-estimates the potential costs to industry of moving to a more circular economy and to pursuing decarbonisation. European industry already has to deal with an uneven playing field e.g. ETS, REACH whereby the standards that are imposed on European operations do not apply to exporters into Europe. If the Commission is to achieve a circular economy, this work must also address issues such as carbon leakage across borders and the lower standards of environmental performance and higher environmental impact that are seen in non-European operations. If this is not addressed, then Europe will continue to consume imported goods made from less sustainable processes and will not make the progress it aspires to on developing a circular economy.
The Commission should also address the issue of competition for the same resource. If all industries in Europe are expected to follow the same timetable then there will inevitably be competition for some resources e.g. renewable energy, recycled plastic and talent/know-how. This competition may distort the economics of the circular economy as well as delaying the implementation of key programmes. Prioritisation of the industrial sectors and guidance on managing resource scarcity should be within the scope of the work.
Read full response6 Feb 2019
The coil coating industry in Europe is an important downstream user of TiO2 as it consumes ~200kt of paint each year for the manufacture of prepainted steel and aluminium for a range of end-uses, such as construction and domestic appliances. The paints are very sophisticated in order to meet both the needs of the production process and to fulfil market requirements; TiO2 is a key component of these paint formulations.
Members of ECCA have the following concerns about the proposed classification of TiO2:
(a) The suspected hazard defined for TiO2 is based on a secondary dust effect observed on rats submitted to inhalation in load conditions exceeding any realistic workplace exposures. It is unrepresentative of the situation that exists within the manufacturing processes used by the paint suppliers to coil coating lines where any exposure to TiO2 in powder form is already minimised through occupational hygiene practices. Coil coating lines typically use TiO2 within a liquid (paint) matrix and the finished product contains no “free” TiO2 for inhalation.
(b) The classification and subsequent product labelling will inevitably lead to confusion (and concern) within the prepainted metal supply chain. Labelling TiO2-containing paints as potentially carcinogenic will generate real concern amongst production operatives on the coil coating lines when, in reality, the TiO2 is bound within the liquid and there is no inhalation risk. Any such labelling also removes the distinction between those paints that may contain other carcinogenic agents for which there is a real potential risk and others where such a risk is not present. The coil coaters are, in many cases, expected to inform their customers e.g. building panel and domestic appliance manufacturers, about the composition and hazards associated with the prepainted product that they supply to them. Many prepainted metal customers operate hazard-based purchasing specifications and the product can be certified to meet various environmental schemes; any labelling of TiO2 as hazardous would put the product at risk of substitution by other materials or out of compliance with the environmental certifications. This information cascade through the prepainted metal supply chain will be unhelpful and potentially alarmist in some end-uses e.g. domestic appliance where there is a strong consumer involvement.
(c) Over 95% of prepainted steel and aluminium is recycled. The classification could result in confusion when operators will have to consider the appropriate waste classification for the corresponding scrap metal, even though TiO2 is generally bound in the organic coating and cannot be inhaled. This is expected to create disruption in certain recycling streams and may lead to more prepainted metal going to landfill and reduced recycling rates.
Because of the sophistication of the coil coating paint, the probability of finding viable alternatives to TiO2 is very low. Work carried out by the leading paint suppliers to the industry has shown that even after intensive R&D development, in the very best case, some companies could find laboratory alternatives to replace only 2-3% of the TiO2 used.
ECCA believes that the current proposal is unnecessary and that any hazards associated with particulate TiO2 could be managed by other means e.g. harmonised OEL’s. The proposal will seriously damage consumer confidence in the prepainted metal product, compromise product performance, and may lead to difficulties in the recycling of the product at the end of its service life. We believe that the proposed regulation is lacking proportionality and will not deliver any measurable benefits for the health of workers and consumers.
Read full responseResponse to Evaluation of the Industrial Emissions Directive
3 Dec 2018
The European Coil Coating Association (ECCA) welcomes the EC commitment to make EU regulation more efficient and effective through thorough, transparent, and critical reviews.
We, however, believe that launching an evaluation of the IED is premature, the main reason being that several important BREFs are still under development and far from being implemented.
In the case of coil coating, the STS BREF TWG final meeting has not event taken place yet so evaluating its implementation is just unrealistic and unfeasable!
Evaluation should be based on solid data that we don’t think is available yet for an accurate analysis. The IED evaluation should be postponed.
Read full response