Page 61 - FINAT Yearbook 2014

Chemicals Agency launched a major enforcement initiative, which has resulted in the notification of thousands of registrants of identified shortcomings in their REACH Dossiers, mainly in the area of substance identification. Given the increased activity of ECHA, I would like to urge any FINAT member who has registered chemicals under REACH to check their REACH-IT mailbox regularly for any correspondence.
Still, REACH has other implications beyond the obligation to register chemicals, which can also directly impact FINAT members. Once again I would like to remind you of the need to check if products contain Substances of Very High Concern, and of the obligation to implement any Risk Management Measures laid out in the new extended Safety Data Sheets.
As a member of the CheMI platform, the platform for downstream users of chemicals in manufacturing industries, FINAT continues to monitor developments in guidance and enforcement of REACH, as well as the Biocidal Product Regulation.
• Biocidal Product Regulation
The status of treated
articles under the
new Biocidal Product
Regulation continues to be a strongly debated topic, with initial guidance from the European Commission raising more questions than answering them. For example, the lack of a cut-off limit meant that even tiniest amount of a biocide (which for example can be used in adhesives) would automatically result in an article falling under the regulation.
After a meeting with the Commission in spring 2014 we understand that this section is to be updated shortly to incorporate input from the industry. If this is actually implemented, it would be a major achievement for the CheMi platform, which has lobbied for this for the last two years.
4. SUSTAINABILITY AND RECYCLING
• Product Environmental Footprint
Following the initial pilot project for paper products, the EU had launched a call for pilots to develop product- group specific environmental footprint tools in 2013. After a long discussion, FINAT decided not to apply for the position of Secretariat, as there were questions regarding the scope, workload and expected results of the project. Instead, the association has participated in the first stakeholder consultation for the pilot for intermediate paper products and will be actively monitoring developments. 3 main groups are supplying data for the project: Packaging paper, graphic paper and tissue.
A second phase of pilot projects, which will cover food and drinks will be launched in May, with packaging also in scope.
• Lifecycle analysis
FINAT has agreed to make a guidance document (white paper) for lifecycle assessment for the self-adhesive label industry, providing guidelines, an explanation of the methodology and available tools, as well as case studies to help member companies develop their own LCA calculations. Consultants are currently being approached with the terms of reference for quotations for this white paper.
• Status of Release Liner under Packaging and Packaging Waste Directive
While discussions concerning the status of release liner at European level have subsided with the release of the amended Annex in 2013, discussions at a national level continue. In the Netherlands, we are supporting the Dutch association KVGO in their legal proceedings with the Dutch tax authorities in this matter.
5. OTHER
• ISO technical specification for labels
Following the first
discussions last
year concerning
the proposed ISO
Work Item for a technical specification for labels, FINAT and representatives of the other national label associations have participated in subsequent meetings. Unfortunately, FINAT had not been able to convince the Swedish Standardisation Institute to stop the project on the grounds of non- feasibility. As yet it is uncertain whether the project will result in a technical specification or a ‘true’ standard’, but discussions will at least go on for approximately two years. In the meantime, FINAT has aligned with VskE in participating in the German standardisation institute DIN’s ‘mirror taskforce’.
IN CONCLUSION
There is never a dull moment in regulatory affairs and 2013 has been a particularly eventful year. In the near future, FINAT will expand its public affairs service to further shift to pro-active legislative advocacy and provide daily public affairs information updates using the FINAT Twitter account, as well as a weekly, dedicated online magazine, serving as ‘early warning tool’ on issues relevant to the industry.
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FINAT YEARBOOK 2014 |