REACH revision delayed: no all-clear just yet

Frankfurt, 20/11/2022

The timetable in the European Commission’s work programme for 2023, according to which the REACH revision will not start at the end of 2022 as previously indicated, is welcomed as an important step in the right direction. The companies represented by TEGEWA – many of which are small and medium-sized enterprises – are heavily affected by the REACH revision and see parts of the currently circulating proposals as existential threats. In addition, as part of an energy intensive sector, TEGEWA member companies are massively experiencing the implications of the current economic and political crisis. Therefore, the original – very tight and ambitious – timetable was considered unsuitable by the industry.                                                 

The work programme mentions a “targeted revision”, instead of the fully comprehensive reform originally envisaged, and indicates the revision for the fourth quarter of 2023. Even though the rescheduling of a few months can only be seen as a small step: with less time pressure and, associated with this, more diligence in drafting, we see the chance that the revision of the REACH Regulation will be approached with a sense of proportion and reason. The EU-REACH legislation in its current form continues to set the strictest global requirements and represents the highest standard for chemical safety worldwide. With its risk-based approach, the regulation is science-based and fact-driven, while providing maximum level of consumer, occupational and environmental protection. On behalf of its members, TEGEWA hopes for a targeted and evidence-based revision – to support the future viability of our and many other industries in Germany and Europe.

First General Assembly of new European Association EUCTL

(Frankfurt, 16-11-2021)

On February 10th, 2021, the first General Assembly of the European Association EUCTL (European Chemistry for Textile and Leather) was held – due to the pandemic situation in form of a virtual conference. EUCTL had been founded in 2020 by TEGEWA and the Italian Chemical Industry Association Federchimica and shall help to achieve better – and earlier – involvement in European legislation processes.

This first General Assembly also comprised the election of Board and Chair Persons. Due to restructuring processes in the membership, the board was forced to make use of its right on cooptation and to determine Dr. Wolfgang Schumann, Rudolf, as successor to the first elected president, Ralf Kattanek. Dr. Filippo Pampagnin, Bozzetto, holds the position as Vice President. Further Board members are :

Roberto Ghioldi,  E.R.C.A. S.P.A.
Dr. Giuseppe Li Bassi,  Lamberti S.P.A.
Dr. Benoit Moutault, CHT Germany GmbH
Marc Smit,  Smit & Zoon B.V.

 

The European Commission’s Chemicals Strategy even outshines REACH

Frankfurt, October 15, 2020

On October 14th, the EU Commission published its “Chemicals Strategy for Sustainability Towards a Toxic-Free Environment”. This strategy – which is meant to be implemented within the next four years, according to the Commission’s intentions – is posing extremely ambitious challenges to chemical industry. Whereas the strategy seems to be at least unrealistic in view of the temporal context, the content-related requirements are even more than ambitious. The member companies of TEGEWA and the management staff of the association itself consider the challenges as bigger than those of the European Chemicals legislation REACH, which came into force in 2007.

The protection of both the environment and human health is a self-evident goal of the association TEGEWA and its member companies. REACH, which is being implemented with all our strength right from the start, is offering all kind of possibilities to identify and regulate harmful or “problematic” substances. How far a „chemicals strategy for sustainability“ with focus on „a toxic-free environment“ can offer a certain added value, is not visible to the association TEGEWA at this point of time.

In close cooperation with the umbrella organisation VCI, the European associations as well as the respective industrial customer’s associations, TEGEWA will accompany the strategy process on all levels and raise the voice of its member companies.

TEGEWA welcomes the EU Commission‘s proposal to further minimize risks of skin allergies that may be caused by chemical substances – but criticises the chosen approach which is overshooting the mark.

Frankfurt, August 19,2020

First, there is – in general – a limited consumer risk from textile and leather articles. Secondly, the restriction proposal is demanding a restriction of all substances with a harmonised classification as „sensitiser“ – completely independent of their actual use in textile or leather production, and not considering whether allergies may be caused by them or not.

This would, in practice, not only lead to an enormous number of unnecessary testing and monitoring costs, because textile and leather articles would have to be tested for non-occurrence of regulated substances – which are not even used for the manufacture of these consumer articles. Many dyes (being used for many years, some of them for decades) would be banned, even though there is no indication that textiles which had been dyed with them have ever caused allergies. As an alternative, the association TEGEWA proposes to regulate well-known, strong sensitisers with individual limits and, by doing so, to focus on real relevance and exposure by those substances through textiles and leather – as successfully implemented in the “Restriction of CMR substances in textile articles and clothing for consumer use under REACH” of 2018.

Background:
In 2019, Sweden and France published a proposal to restrict sensitising substances in textiles and leather. Not only textile and leather industry themselves, but also the textile and leather auxiliaries industry as well as the dyestuff industry are affected by this proposed restriction. This had been the reason for the association to develop a joint position on this first restriction proposal with its member companies, the international organization representing the dye and pigment industries ETAD and various German and European textile and leather industry associations. The association’s comments on this proposal had been submitted at the first public consultation in December 2019. Following the common legislative process in the EU, the two ECHA committees RAC (Risk Assessment Committee) and SEAC (Socio-Economic Analysis Committee) discussed the submitted comments and developed their opinions.

SEAC’s „Draft Opinion“ had been subject to a further public consultation (deadline August 24th). Due to the high relevance and importance of this topic, TEGEWA developed and submitted (again in cooperation with the above mentioned associations) a further position regarding the SEAC draft opinion (see weblink of this post to ECHA’s website). Focus of this position was an extensive argumentation against the intended restriction of specific disperse and reactive dyes. For textiles that have been dyed with these substances there is no indication – neither from the view of market relevant dyes manufactures nor from the view of the associations ETAD and TEGEWA – of sensitising effects to consumers by leather or textile articles.

On the other hand, these dyes do have – for decades – such a huge market relevance, that a ban would imply incalculable consequences for the companies producing dyes; for the textile and leather dyeing companies as well as for the consumers who could not purchase numerous articles any more.

As an alternative, the association developed a process based on a list of substances which can in fact be present on textile and leather articles and may lead to allergies to consumer. This process is also comprising a course of action regarding a regular update of the substances concerned – after verification whether they are relevant or not.

Apart from these important dye classes the association TEGEWA also pointed out implications for the manufacture of leather and textile articles; among others flame retardant and non-iron finishing of textiles and tanning of leather. Furthermore, TEGEWA sees a high risk for the European textiles and leather producers, as especially the European industry will be affected by the restriction – whereas, in parallel, articles are imported from outside the EU with unclear quality and consumer exposure.

The association TEGEWA is doing its best to contribute to a regulation as reasonable and justifiable as possible which actually is helping to improve consumer safety.

Fluorochemistry – TEGEWA participates at Cross-Sectoral Information Session

Various European regulatory activities with regard to fluorochemistry – either implemented or still in development – show far-reaching consequences for the whole textile supply chain. That’s the reason for the contribution of TEGEWA to the comprehensive, web-based conference on July 23rd about „the Cascade of REACH Restrictions in Fluorochemistry“. The information session had been a joint project of the associations VTB (Verband der Bayerischen Textil- und Bekleidungsindustrie), Südwesttextil, textil + mode, VCI Bayern and TEGEWA and addressed a large-scale target audience at European level. Along with representatives of textile chemistry companies, from politics and authorities, especially representatives of customer’s industry joint the session in order to inform themselves about the current developments with regard to REACH legislation on fluorochemistry. This is, among others,

  • The restriction process on undecafluorohexanoic acid (PFHxA) and fluorinated polymers that are used in textile industry (public consultation ends September 25th)
  • As well as the „Call for Evidence“ regarding an intended restriction of the whole fluorochemistry (PFAS) in the EU (public consultation ended July 20th).

The audience had been invited to make submissions to the public consultation on the restriction of PFHxA. Further information regarding the information session as well as the presented slides can be downloaded e.g. from the website of the VCI Bayern.

Moving towards Europe: TEGEWA and Italian chemicals association Federchimica are founding European association of manufacturers of textile and leather chemicals (EUCTL, European Chemistry for Textiles and Leather)

In order to accompany European and international issues even more efficiently, TEGEWA and Federchimica founded the association „European Chemistry for Textiles and Leather“ (EUCTL) on June 8th, 2020. The statutes which had been signed by the authorised representatives of both founding members will now have to be confirmed by the Belgian bodies.

This will take approximately three months – during this time, all necessary organisational preparations will be started to establish the new association as an active European body in Brussels in autumn 2020. TEGEWA and Federchimica hope to achieve better – and earlier – involvement by EUCTL in European legislation processes and to be able to actively accompany those in future.

Even if the two founding members are representing the major part of textile and leather chemical industry in the European Union, further organisations of additional EU countries are welcomed to join EUCTL. Strategical partnerships with additional, European or global acting organisations are imaginable as well.

Master’s Course “Sustainable Textiles” at Hof University

The TEGEWA Steering Group Textile Auxiliaries has established an endowment professorship for the master’s course „Sustainable Textiles“ at the Hof University/Abt. Muenchberg which started in summer term 2020 on April 20th (later than originally planned because of the current pandemic situation).

This English-taught, postgradual master’s Course is a dual one, meaning: In parallel with the course of study, a traineeship at a company (textile chemicals manufacturer) is obligatory.

The master’s course “Sustainable Textiles” is combining textile chemistry and sustainability in the textile supply chain in a unique way. By linking theory and practical applications the students are receiving the best possible preparation for a future career in this exciting and innovative professional field. To find more information just visit the university’s website! 

Position „Cyclic Siloxanes on Candidate List“

The European Chemicals Agency (ECHA) decided in June 2018 to include the substances

  • D4 (Octamethylcyclotetrasiloxane)
  • D5 (Decamethylcyclopentasiloxane) and
  • D6 (Dodecamethylcyclohexasiloxane)

on the EU REACH Candidate List for Substances of Very High Concern (SVHC).

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TEGEWA method for determining cyclic siloxane levels in textile auxiliaries

In recent years, the cyclic silicones D4 (Octamethylcyclotetrasiloxane) and D5 (Decamethylcyclopentasiloxane) started to gain attention by national as well as European authorities. Some regulatory activity has been carried out, inter alia a restriction procedure for D4 and D5 in certain cosmetic uses (shampoos, conditioners) on EU level and the inclusion on the EU Candidate List for of substances that may require further regulatory measures under the European chemicals Legislation REACH.

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