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Federatie Nederlandse Rubber- en Kunststofindustrie

Federatie NRK

The Dutch Federation of Rubber and Plastics Industry NRK represents the interests of some 400 companies grouped into 20 industry associations.

Lobbying Activity

Response to Commission Regulation amending Annex XIV to REACH

22 May 2019

NRK, he Dutch Federation of Rubber and Plastics Industry, represents the interests of some 420 companies grouped into 19 industry associations. We are working together on a healthy business climate for the manufacturing industry and stimulate competitiveness, innovation and knowledge transfer, education and training, a better environment and recycling. NRK would like to highlight our concerns regarding the inclusion of ADCA in the proposal to amend Annex XIV of Regulation 1907/2006. We would express our objections to the suggestion to list ADCA in Annex XIV, given the substantial impact that such legislative change would have. 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, we believe that alternative policy measures should be considered to boost ongoing efforts to minimize exposure in the workplace. We therefore support the proposal of the ADCA Task Force that calls 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. ADCA is a key blowing agent, used in a number of sectors and products, such as flooring, wall covering, pipes, insulation, PVC artificial leather for upholstery and PVC-foams, crosslinked polyolefin foams. Several of our member companies (Veritex and Sekisui Alveo) and European organistions (ETRMA, Eppfa and the ADCA Task Force) described the use of ADCA, the benefits , alternatives and impact of Annex XIV listings. We support their arguments and views.
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