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EU: EU launched public consultation on MCCP under REACH Annex XVII

SEPTEMBER 2022 - ELECTRICAL AND ELECTRONICS, HARDLINES, SOFTLINES, TOYS AND CHILDREN'S PRODUCTS

On 21 September 2022, the European Chemicals Agency (ECHA) launched the 1st public consultation1 on the proposal2 to restrict medium-chain chlorinated paraffin (MCCP) and other substances that contain chloroalkanes with carbon chain lengths from C14 to C17 (CA:C14-17) under REACH Annex XVII. 

The restriction report submitter proposed to restrict the presence of CA:C14-17 constituents (congeners) with PBT and/or vPvB properties. MCCP belongs to this group of substances and has been listed on the REACH Substance of Very High Concern (SVHC) Candidate List for authorisation since 2021. According to the Annex XV report, substances containing CA:C14-17 are mainly used as flame retardants and secondary plasticising additives in various materials, e.g. plastics, sealants, rubber and textiles. As the risk of exposure to these substances is not adequately controlled, a proposed restriction under REACH Annex XVII is required. Moreover, the discussions concerning the POP listing of chlorinated paraffin with carbon chain lengths in the range C14-17 and chlorination levels at or exceeding 45% of chlorine by weight under the Stockholm Convention3 are ongoing.

The public consultation will end on 22 March 2023, and the final opinion of ECHA is expected to be available by September 2023. After that, ECHA will send the final opinion to the European Commission (EC), which will make the decision on whether to include the proposed restriction in REACH Annex XVII. Table A shows the details of the proposal.

Abbreviations:

  • PBT: Persistent Bioaccumulative and Toxic
  • vPvB: very Persistent very Bioaccumulative
  • POP: Persistent Organic Pollutants

Table A.  Proposal of chloroalkanes:C14-C17 restriction under REACH Annex XVII 

Restricted substance Medium-chain chlorinated paraffins (MCCP) and other substances that contain chloroalkanes with carbon chain lengths from C14 to C17 (CA:C14-17)
Proposed scope of restriction
Substances, mixtures and articles
Proposed limit

Substances, mixtures, articles: < 0.1% weight by weight

Information requirements: 
Within 6 months after entry into force,

  • The suppliers of regulated substances shall conclude and identify the substances as PBT and/or vPvB unless they can demonstrate that the overall upper concentration of the chloroalkanes is lower than 0.1% weight by weight;
  • The supplier placing on the market substances, mixtures, or articles containing the chloroalkanes shall inform their downstream users and customers of 

(i) the presence and overall concentration of the chloroalkanes; and

(ii) the appropriate risk management measures and operating conditions to minimise the releases and exposure in case of the presence of chloroalkanes.

Proposed exemption
  • Articles already in use and second-hand articles which were in end-use before the date of entry into force;
  • Reference materials and standards for analytical purposes;
  • Extreme Pressure Additive for metalworking fluids for 7 years after into force.
 
Proposed date of application

 2 years after the date of entry into force 

[1]  Public consultation summary

[2]  Annex XV Report submitted for the restriction proposal

[3]  On-going discussion in relation to the POP listing of MCCP under the Stockholm Convention 

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