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Imerys SA

Imerys

Imerys is the world leader in mineral-based specialty solutions for industry, with 13,000 employees, 200 industrial sites located in 40 countries and €3.6 billion in sales in 2024.

Lobbying Activity

Meeting with Pierre Jouvet (Member of the European Parliament)

29 Apr 2025 · Echange sur la filière européenne du corindon

Meeting with Christophe Grudler (Member of the European Parliament)

29 Apr 2025 · Politique industrielle européenne

Meeting with Raphaël Glucksmann (Member of the European Parliament)

29 Apr 2025 · Trade defence

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

29 Apr 2025 · Talc

Meeting with Stéphane Séjourné (Executive Vice-President) and

19 Feb 2025 · Dialogue on the future of the automotive sector – Battery Session

Meeting with Thierry Breton (Commissioner) and

5 Apr 2023 · Comments on critical raw materials act

Response to Co-formulants in pesticides

13 Feb 2020

We, Imerys SA, hereby ask for the removal of the naturally occurring mineral “Aluminium silicate (kaolin)” from the draft list of unacceptable co-formulants in Annex III of Regulation (EC) 1107/2009 and for the revision of the limit on quartz sand as an unintentional impurity. We understand that aluminium silicate (kaolin) is under consideration because of its potential to contain low levels of crystalline silica as an unintentional impurity. However crystalline silica does not have an EU harmonised classification and thus is not listed in the Annex VI of the CLP Regulation. Respirable crystalline silica is strictly legislated at the workplace. In 2018, ‘works involving exposure to respirable crystalline silica (RCS) generated by a work process’ were included in the European Carcinogens and Mutagens at Work Directive [Directive (EU) 2017/2398] with a Binding Occupational Exposure Limit Value of 0.1 mg/m³. A recent report on crystalline silica by ANSES (French Agency for Food, Environmental and Occupational Health & Safety) in France concludes that there is no consumer use leading to a significant exposure to crystalline silica by inhalation and the professional users are protected by the Carcinogens and Mutagens Directive and the maximum exposure limit which is set in it. Thanks to the provisions of the workplace legislation, aluminium silicate (kaolin) has no harmful effect on human/animal health or environment through its use as co-formulant in PPPs and certainly has no unacceptable effect on plants as any soil contains a high proportion of silica and clay by nature. Indeed, the earth’s crust consists of 12% quartz (the most common form of crystalline silica), which makes it the second most abundant mineral on the earth’s surface. Because kaolin is a mineral of natural origin, the crystalline silica contained in it is also of natural origin and can only be removed to a certain point. Therefore, setting a limit as unintentional impurity of 0.5 % (weight by weight (w/w) on quartz sand (containing > 0.1 % particles with diameter below 50 um) is unrealistic from an industrial mineral perspective. The limit currently used for the non-classification of substances containing respirable crystalline silica impurities is <1% with <10 um particle size. In addition, the reason for banning a co-formulant as written in point (3) of the recital is: “Co-formulants are substances or preparations used together with active substances in plant protection products and are thus equally spread in the environment. Therefore, the criteria concerning human health, the environment, ecotoxicity and groundwater [...] should also be relevant to identify unacceptable co-formulants.” Aluminium silicate (kaolin) is authorised as an active substance at EU level. Formulations based on this active substance are authorised at national level and are recognised for use in organic farming. Therefore, on which grounds can an active substance simultaneously be banned as co-formulant?
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