On June 1, 2020, regulatory news provider Chemical Watch published an article providing an overview of the progress being made by three of the EU’s chemical assessment programs. These include (i) the Community Rolling Action Plan (CoRAP) for the years 2020-2022, (ii) the review program of active substances under the Biocidal Products Regulation (BPR), and (iii) substances being evaluated under the Restriction of Hazardous Substances (RoHS) Directive.

Based on the listing by several regulatory and industry sources on food contact chemicals, as compiled by the Food Packaging Forum in its Food Contact Chemicals database (FCCdb), many of the chemicals highlighted by Chemical Watch could potentially be used in several types of FCMs and FCAs, including

Chemicals on the CoRAP for the years 2020-2022:

  • bis(4-hydroxy-N-methylanilinium) sulphate (CAS 55-55-0); potentially used in printing inks
  • 4-aminophenol (CAS 123-30-8); potentially used in printing inks
  • phenol, isopropylated, phosphate (3:1) (CAS 68937-41-7); potentially used in printing inks and plastics
  • 3-methyl-1,5-pentanediyl diacrylate (CAS 64194-22-5; substance recently withdrawn from evaluation); potentially used in printing inks and coatings

Chemicals in the BPR review program:

  • 2-benzyl-4-chlorophenol (CAS 120-32-1); potentially used in plastics and as a sanitizer
  • glyoxal (CAS 107-22-2); potentially used in plastics, coatings, paper/board, cellophane, textiles, adhesives, printing inks
  • isopropanol (CAS 67-63-0); potentially used in plastics, coatings, rubber, silicones, IERs, paper/board, cellophane, textiles, cork/wood, adhesives, colorants, printing inks, and in lubricants for metallic articles
  • 5-chloro-2-methyl-4-isothiazolin-3-one (CMIT; CAS 26172-55-4); potentially used in plastics, coatings, rubber, silicones, paper/board, cork/wood, adhesives, colorants, printing inks, active & intelligent materials
  • methylisothiazolinone (MIT; CAS 2682-20-4); potentially used in plastics, coatings, rubber, silicones, paper/board, cork/wood, adhesives, colorants, printing inks, active & intelligent materials
  • peracetic acid (CAS 79-21-0); potentially used in plastics, IERs, paper/board, cellophane, cork/wood, colorants, printing inks, and as a sanitizer or antimicrobial, e.g., in washing aids
  • hydrogen peroxide (CAS 7722-84-1); potentially used in plastics, coatings, rubber, silicones, IERs, paper/board, cork/wood, adhesives, printing inks, active & intelligent materials, and as a sanitizer, sterilizer, or antimicrobial, e.g., in washing aids

Chemicals evaluated under the RoHS Directive:

  • cobalt sulphate (CAS 10124-43-3); potentially used in coatings, paper/board, and printing inks
  • cobalt carbonate (CAS 513-79-1), potentially used in coatings and printing inks
  • cobalt di(acetate) (CAS 71-48-7), potentially used in plastics, coatings, paper/board, adhesives, printing inks
  • cobalt dichloride (CAS 7646-79-9); potentially used in plastics and coatings
  • diantimony trioxide (CAS 1309-64-4); potentially used in plastics, coatings, rubber, textiles, adhesives, colorants, printing inks, and inorganic FCMs
  • medium chain chlorinated paraffins (MCCPs; CAS 85535-85-9); potentially used in printing inks
  • tetrabromobisphenol-A (TBBPA; CAS 79-94-7); potentially used in plastics, adhesives, and printing inks
  • beryllium (CAS 7440-41-7); potentially used in inorganic FCMs, e.g., metal alloys; beryllium oxide (CAS 1304-56-9) can also be present in ceramics

Substances set for review within the CoRAP program will now be assessed by EU member states in the coming months and years. Registrants of the chemicals under REACH may be asked by authorities to provide more information, and the assessment could deem that additional risk management measures are needed. A draft list of substances to be added to the CoRAP is set to be published in the Fall of 2020 and updated in March 2021. For substances within the BPR review program, opinions from the assessments of some of the substances are either already available or set to be published soon. For the others waiting to be assessed, a decision could be made in the coming months on whether or not to approve them in biocidal applications. The responsible review committee was set to meet in June 2020, and the entire program is scheduled to end in 2024. Similarly, some of the substances being reviewed under the RoHS Directive have already completed their assessments and received recommendations for use restrictions, while others are still pending review.

The above analysis demonstrates that many hazardous substances which are being assessed within several EU programs focused on industrial chemicals could in fact also be used in FCMs, which are presently subject to a different set of regulations. The recently published Roadmap for the EU Chemicals Strategy for Sustainability indicated that the European Commission wants to simplify and strengthen the legal framework related to chemicals by moving towards a “one substance – one assessment” process across regulatory silos (FPF reported). In its response to the EC’s Roadmap, the Food Packaging Forum highlighted the inconsistencies in EU chemicals regulation and emphasized the need to prioritize substitution of known hazardous chemicals used in FCMs (FPF reported).

Read More

Cristina Garcia (June 1, 2020). “Global Outlook Update: How are Europe’s key chemical assessment programmes progressing?” Chemical Watch

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