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EU: POPs recast proposal brings PCP article restriction

may 2018 - Relevant for: Electrical & electronics, Hardlines, Softlines, Toys and Children's products INDUSTRY

The European Commission recently proposed to recast EU POPs Regulation (Persistent Organic Pollutants). This recast was to update the repealed regulatory procedures and align with the Lisbon Treaty; introduce the European Chemicals Agency (ECHA) to handle technical matters related to POPs Regulation. Most importantly, the Annexes of POPs is proposed to include new POPs from the Stockholm Convention. Pentachlorophenol and its salts and esters (PCP) may be restricted under Part A of Annex I of the POPs Regulation.

PCP has been widely used as biocides such as insecticides, herbicides and fungicides, etc. It also can be used in leather and wood preservatives. Owing to its high toxicity, PCP was substituted with other alternatives and its usage has decreased over decades. PCP can be found in textiles, leather, wood and paper in consumer products as residues. Articles containing PCP are regulated by various EU Member States including Germany, Austria and the Netherlands.

Although PCP is harmful to humans and the environment, no EU wide legislation regulates articles containing PCP. The EU POPs Regulation may be an appropriate measure to address the risks. Table A summarises the current and proposed PCP restriction in the EU.

In addition to PCP, polychlorinated naphthalene (PCN) and hexachlorobutadiene (HCBD) may be newly included in Part A of Annex I of the POPs Regulation. PCN is used for insulating coatings for electrical wires, additives in plastic and rubber and in lubricants. HCBD can be formed unintentionally during the production of some chlorinated hydrocarbons such as polyvinyl chloride.

Table A. Comparison of current and proposed PCP restriction in the EU

Reference

Substances

Mixtures

Articles

REACH Regulation, Annex XVII of entry 22

Not used

0.1% by weight

No requirement

POPs Regulation (Proposed)

Not used

Not used

Not used

  1. POPs Recast – Draft Legal text
  2. POPs Recast – Draft Annex

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