“Euro Chlor’s Product Groups add value by optimally engaging with key stakeholders on behalf of their membership”
Communications and collaboration
Communications: new website highlights benefits of chlorinated solvents
Early in 2020, ECSA launched its new website. This new online portal has been designed to promote the benefits of chlorinated solvents and their products, whilst sharing information on best practices in sustainability, safety and technology and the latest information on regulatory issues. The next step in this website development process is to update all the documents featured there with the latest ECSA information. The site is available at
Collaboration increasing with international associations
US sister organisation Halogenated Solvents Industry Alliance, Inc.(HSIA) invited ECSA to participate in its 11 June 2020 Board of Directors meeting. Here, ECSA Sector Group Manager Angelica Candido and member company (Inovyn) representatives Chris Howick and Neil Rosenburgh (also ECSA Chair) shared key information. Click here for more details.
EC Ozone Depleting Substances (ODS) Regulation
ECSA is monitoring several regulatory topics. In March 2020, the European Commission (EC) published the results of its evaluation on the Ozone Depleting Substances (ODS) Regulation finding that it:
- Achieved its objectives: ensuring compliance with the international agreements on the protection of the ozone layer and having a high level of ambition for protecting the ozone layer and fighting climate change;
- Remains highly relevant and has a clear EU added value. Only a common, harmonised EU approach can implement the Montreal Protocol’s obligations and respect internal market rules;
- Is in general well-aligned with relevant EU and international legislation;
- Is efficient, but some results may be achievable through simpler, less resource-intensive activities.
Substances supported by ECSA and listed on the ODS Regulation are carbon tetrachloride (CTC) (Annex I, restrictions and reporting) and methyl chloride (MeCl) (Annex II, reporting only, no restrictions). For additional information, click here.
German MAK Commission
In Germany, the MAK Commission is the key institution for deriving scientific-based occupational exposure limits (OELs) which are applied at national level. Their assessments are also of high relevance for European authorities and international advisory bodies such as the International Agency for Research on Cancer (IARC).
Early in 2020, the MAK Commission requested and gained access to an OECD 414 developmental toxicity study of MeCl on rabbits, commissioned by industry. This was because the MAK Commission were requested by the Bundesanstalt für Arbeitsschutz und Arbeitsmedizin (BAuA, the German Federal Institute for Occupational Safety and Health) to re-evaluate MeCl. Back in early 2019, industry prepared a scientific publication in a peer-reviewed journal on the results of the study, and its relevance in view of older data, with the intention to inform regulators and advisory bodies globally on its positive outcome.
The MAK Commission concluded that there is no reason to classify MeCl for skin absorption, sensitisation, carcinogenicity and mutagenicity, as was partially done in previous assessments. The proposal will now undergo consultation with presentation of any additional scientific information by the end of 2020. The new classification proposal is expected to become official in 2021.
UBA PMT approach
Perchloroethylene (PER) is considered to be persistent, mobile and toxic (PMT) under criteria set by Germany’s Umweltbundesamt (UBA, the German Federal Environment Agency). The PMT criteria could be used to identify substances of very high concern (SVHC) for inclusion in the candidate list for authorisation under REACH, and the Stockholm Convention on Persistent Organic Pollutants (POPs). An EU Science Committee identified PMT substances as one of 14 emerging issues that could impact human health or the environment in the future. ECSA has argued that a risk-based approach should be taken, particularly as PER is used in closed systems with negligible risk of environmental emissions. ECSA has shared its position with Cefic, national industry associations and EU and national authorities and is closely following the scientific and regulatory discussions. Click here for more information.
Other ongoing topics include the global Montreal Protocol on ODS.
Building understanding with Chloro Alkanes Product Group (CAPG)
The CAPG has worked this year to improve authority and academic understanding on this group of versatile chemicals.
With the conclusion of the REACH Substance Evaluation for MCCP, CAPG is now helping to connect the MCCP REACH consortium with authorities. This will ensure that they are well-briefed on the most up-to-date science for the next phase of the assessment.
The group have also supported several key conferences in 2020. In May, they presented at SETAC (a large academic/regulator/industry environmental chemistry conference). In August they held a webinar with academics to discuss state-of-the art techniques to analyse chloro alkanes. They are also holding an international webinar in September 2020 to brief global audiences on the regulatory status of chloro alkanes around the world.
Finally, CAPG are sponsoring an Intertek project to prepare a PVC cable life-cycle assessment and worker exposure study. This will provide authorities with useful information on MCCP as part of an ongoing assessment under the Restriction of Hazardous Substances in Electronics and Electronic Equipment (RoHS) Directive. Here, an uninformed risk assessment by the German Oeko Institut seems to recommend a restriction for MCCP, which the group hope to help improve.
New Sector Group on chloroformates
As a first activity, the group will prepare an advice document on how to safely handle, transport and store drums of the most hazardous chloroformates. Anyone who is interested in supporting the drafting of this document, or in participating in group activities, should contact Richy Mariner.
Other Euro Chlor/Halogens industry sector news
Euro Chlor operates within the Euro Chlor/Halogens industry sector cluster as part of Cefic. This brings together a cluster of inorganic basic chemicals that are essential building blocks to manufacture a multitude of products. Here are the past year’s highlights from the two related sister SGs:
EFCTC (European FluoroCarbons Technical Committee)
EFCTC has continued its intense work started last year to combat a rapid emergence of illegal imports of hydrofluorocarbons (HFCs/refrigerants) into the EU. This has involved the ramp-up of its campaign with a project featuring the following multiple levels:
- Extending investigation activities by an external consultant to collect and analyse data and take direct action. These include a whistle-blower line, online marketplace tool and outreach to law enforcement agencies in the Member States.
- Trade data analysis of HFCs by a consultant to identify discrepancies between Eurostat, Comrade and Chinese datasets.
- A Public Relations and Communications programme by a PR consultant in collaboration with Cefic. This includes the publication of articles in international newspapers and press releases, and a new campaign-related microsite (stopillegalcooling.eu) and logo.
- An ongoing Public Affairs programme, including proactive meetings and collaboration with Member States, relevant EU institutions, MEPs and other EU and non-EU bodies.
- A Customs project with practical seminars/webinars to be held for customs officials.
- A Legal working group, providing support to the campaigns working groups above.
At the same time, the EFCTC General Assembly has been working on the review of the F-gas Regulation (2022) with related association European Partnership for Energy & the Environment (EPEE). EFCTC is preparing a mini-website dedicated to the 2020-2022 review and revamping its main website with a new logo, in line with the Illegal Imports of HFCs campaign.
Eurofluor (CTEF, Comité Technique Européen du Fluor)
Eurofluor keeps its strong focus on ensuring the safe production, use, handling, storage and transport of hydrofluoric acid (HF). Work on the internal exchange of best practices for safer industry behaviour also continues, alongside efforts to improve the group’s website.
In 2019, the group launched an exercise to compare its safety guidelines with similar associations in the US and UK, to facilitate and harmonise safety information worldwide.