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European Resilient Flooring Manufacturers’ Institute

ERFMI

ERFMI is formed to represent the interests of the resilient flooring industry in ensuring the maintenance of high ethical standard within the industry through the following activities: 1. obtaining and disseminating to members such relevant information about the resilient flooring industry as may be considered desirable; 2. representing the industry in negotiations with government departments, public bodies, trade associations, non governmental organisations and similar bodies in the European market on matters relating to the resilient flooring industry; 3. promoting the preparation of international standards, specifications and classification systems and their adoption; 4. promoting any activities that further the interests of the resilient flooring industry. ERFMI will specifically avoid any activities that shall prevent, restrict or distort competition between and among members.

Lobbying Activity

Response to Review of the Construction Products Regulation

12 Jul 2022

The European Resilient Flooring Institute, ERFMI, welcomes the Commission’s proposal for a new Construction Products Regulation and appreciates the Commission’s commitment to solving the issues construction products’ manufacturers have been facing over the past few years. The attached document highlights the key points which we believe raise concerns or require clarification.
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Response to Commission Regulation amending Annex XIV to REACH

2 May 2019

The European Resilient Flooring Association, on behalf of its 17 members, representing more than 90% of the resilient flooring produced in Europe, would like to express its concerns regarding the proposal to list ADCA on Annex XIV within the framework of the REACH Regulation ADCA is a blowing agent widely used in the plastics industry. It is estimated that in Europe between 2 and 3 million tonnes of plastics products are foamed with ADCA, covering different sectors: building and construction, automotive and consumer products. New evidence on toxicological properties and exposure information question the appropriateness of the Commission proposal to include ADCA in the REACH authorization list (Annex XIV) for its respiratory sensitising properties (REACH, Article 57(f) - human health). Updated information on the use of ADCA in the plastics sector, medical data, exposure and impacts of the proposed measure have been developed by the European Plastics Converters Trade Association, EuPC [M. Perfetti, G. Tillieux, (2019), EuPC Report on the exposure to ADCA blowing agent, associated risks, its alternatives in the plastics converting industry and socio-economic impact of a potential authorization and non-use scenario, PCE]. Referring to both official statistics and a retrospective medical survey referred to the last 20 years and carried out in January 2019 among the companies using ADCA in the plastics sector, 3 cases of occupational asthma were found, even though the occupational nature of the cases still remains uncertain. These findings suggest that, in the plastics sector where ADCA is used, the risk of exposure is adequately controlled. Alternative policy measures could be considered to further minimize workplace exposure. For example, the implementation of occupational exposure limits for the use of ADCA in the UK in 1996, seems to have been an appropriate risk management measure, as since that period virtually no occoputional health cases directly related to ADCA have been recorded. The inclusion of ADCA in Annex XIV would immediately cause the loss of 4,000-6,350 jobs across the supply chain within the EU and a revenue loss of € 1.3-2.2 billion expressed as yearly turnover mainly caused by delocalisation/investments not renewed. At the same time, a non-use scenario (authorisation not granted) would cause a job loss of 17,400-17,900 workers and a revenue loss of € 3.4-3.5 billion expressed as yearly turnover. As a consequence, we are extremely concerned about the negative effect of the inclusion in the authorisation list on both employment and economy. The European Resilient Flooring Manufacturers’ Institute (ERFMI) represents the interests of 17 manufacturers of resilient floor coverings across Europe. Resilient floor coverings are used in both commercial and domestic applications and can be made of Vinyl, Rubber, Linoleum, Cork, Polyurethane and Synthetic Thermoplastic Polymers. Our members in total employ more than 11,000 people across Europe and manufacture more than 370 million m2 of resilient floor covering per year. ADCA is used as a foaming agent in the production of a large number of resilient flooring products and currently there is no known alternative which can achieve the same quality and properties of the end product. Inclusion of ADCA in ANNEX XIV would create uncertainty, threat of severe competitive drawbacks to EU producers and could lead to job losses in the EU as companies that have the possibility to move their production to regions where the use of ADCA is allowed, may do so. Therefore ERFMI believes that the authorization process for ADCA should be stopped, as it is not a proportionate risk management option and alternative regulatory options, should be considered, such as putting in place the necessary steps to establish an Occupational Exposure Limit value at European Level.
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Meeting with Jean-Luc Demarty (Director-General Trade) and Tarkett and Beaulieu International Group

7 Dec 2015 · Turkish import surveillance measures