10 Aug 2018
ECHA Calls for Evidence on Hazardous Substance Used in Food Contact Materials and Electronics, Among Other Products
The European Chemicals Agency (ECHA) has issued a call for information on uses of Perfluorohexane-1-sulphonic acid (PFHxS), its salts and related substances. Norway is currently preparing an EU-wide restriction proposal for PFHxS, which would restrict the substance in articles. The call for evidence is intended to provide the necessary factual background for an assessment of the socio-economic consequences of such a restriction proposal.
The substance PFHxS and its salts were identified as substances of very high concern (SVHC). They may be present in fire-fighting foams, food contact materials, water/stain proofing agents, cleaning and polishing products as well as electronic equipment, semiconductors and metal plating.
The substances are also used as raw materials for the production of products made from per- and polyfluorinated substances (PFAS) and can be unintentional by-products of certain industrial processes. PFHxS, for instance, is also known as an impurity.
Several of these applications might be of interest to Hong Kong sellers, who may wish to take part in the call for evidence by gathering and furnishing such evidence to ECHA. The ECHA website provides an online submission form for those who wish to do so. The consultation is open until 22 August 2018.
ECHA is particularly interested in possibilities for substitution of the substance, potential suitable non-fluorinated alternatives available on the market and the economic impacts of substitution. Companies are invited to point out specific challenges they might face in the process of substitution and the time necessary to remove potential barriers. Information on emissions, and on the use of the substance in articles, is also of interest. The information will, moreover, be used in order to specify if particular derogations are needed.
The call for evidence targets all who might be potentially affected or involved. It is of course aimed at all manufacturers and all links within the supply chain (importers, distributors, retailers) and professional users. Furthermore, trade associations, consumer and environmental NGOs, research institutes and academia are invited to contribute, as well as EU Member States and individuals.
Hong Kong companies familiar with the substance and its uses may recall that PFHxS and its salts were identified as SVHC in July 2017 due to their very persistent and very bioaccumulative (vPvB) properties according to the REACH Regulation. The concerns over PFHxS are similar to the concerns over other PFASs which are already regulated. Due to their high persistence, global distribution and toxicity, some PFASs have been included in the Stockholm Convention as persistent organic pollutants (POPs).
Back in 2009 a consensus had already been reached among governments to restrict the use of two PFASs within the global Stockholm Convention on POPs: perfluorooctane sulfonic acid (PFOS) and its salts, and perfluorooctane sulfonyl fluoride (PFOS-F). The information that will be gathered by the present call for evidence will also serve as a basis for the global regulation process for PFHxS and PFHxS-related substances under the Stockholm Convention.
The restriction proposal is expected to be submitted to ECHA by Norway in April 2019. After the submission of the proposal, there will be another public consultation, where stakeholders will be able to once more express their views.
Due to the similarities with other PFASs, it can be assumed that the restriction proposal will be similar, too. This means that tolerated limit values will probably be low and that articles, substances and/or mixtures containing impurities of the substances could be covered as part of a future restriction measure.