Page 51 - FINAT Yearbook 2015

we will have a meeting with the Commission end of May 2015 in order to clarify the process and input needed from our side. The revision is expected to be started in Q4 2015 and take around 2,5 years before conclusion.
3. REACH, CLP AND BIOCIDAL PRODUCT REGULATION
REACH
When it comes to the largest piece of chemical legislation in the world, REACH, 2014 has been a relatively quiet year, following the registration deadline in 2013. However, there have been a number of developments in enforcement as well as the chemicals, which have been identified as possibly of very high concern. These lists are updated multiple times per year and 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 (see below).
CLP
2014 was the last full year of the transitional period for the Classification, Labelling and Packaging Regulation (CLP). From 1 June 2015, the Classification, Labelling and Packaging (CLP) Regulation will be the only legislation to apply to the classification and labelling of both substances and mixtures. CLP requires companies to classify, label and package their hazardous chemicals appropriately before placing them on the market. An enormous number of products must be re-labelled to comply with CLP, including consumer items such as paints or detergents, as well as industrial mixtures.
Biocidal Product Regulation
The European Commission has been receptive of the arguments put forward by the CheMi platform to be included in the guidance document on treated articles under the Biocidal Products Regulation. The original guidance was hotly contested and would certainly have caused problems for the industry.
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. We are pleased to see that the lobbying efforts are paying off in this area.
4. SUSTAINABILITY AND RECYCLING
Waste Framework Directive & Packaging and Packaging Waste Directive
Last year, the European Commission issued a communication “towards a circular economy”, which discussed the strategy and actions needed in the Waste Framework Directive and related areas to move to a more competitive resource-efficient economy. Part of the communication focussed on updated recycling figures. FINAT, together with the other member associations involved in CITPA (European confederation of paper and board converting packaging associations), drew up a position paper in response, welcoming the initiative, but also calling attention to some of the questions we had.
In the end, the circular economy package as proposed was withdrawn, and has been on the shelves ever since. In June 2015, the Commission will engage stakeholders again to decide how to move forward in this important area and FINAT will be sure to be there.
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 Austria, authorities have moved to classifying liner as packaging waste.
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FINAT YEARBOOK 2015 |