1. Guidance on labelling of products or articles that contain new POPs or use new POPs during manufacture Scope, target audience, content, example

2. 2 Outline of the presentation Scope of the guidance Target audience Analysis of existing labelling schemes – How systems were analysed – Types of systems analysed Use of the guidance

3. 3 Scope of the guidance The Guidance should facilitate Parties’ efforts to monitor POPs within their territory and their export/import: labelling of products and articles during production ensures that information on their POPs content is clearly indicated this information is disseminated along the supply chain stakeholders can identify and manage the POPs safely The objective of the guidance is: to assist Parties in developing labelling schemes for products and articles to understand the essential elements of such schemes to adapt existing international labelling schemes to national or international needs

4. 4 Target audience National policy makers to prevent illegal import of banned POPs or severely restricted POPs National organisations involved in Standard setting Authorities involved in the collection of information on new POPs Conference of Parties of the Stockholm Convention to discuss and decide on the implementation of labelling schemes for POPs International bodies responsible for labelling schemes to further develop existing labelling schemes to cover POPs adequately, e.g.: GHS Subcommittee of UNECE International Standard Organisation (ISO) International industry associations

5. 5 ANALYSIS OF EXISTING LABELLING SCHEMES

6. 6 How to analyse labelling systems? Existing labelling systems are analysed for the following factors: The aim, objective, content, and basis for the system Whether the system is voluntary or legally binding What will be labeled, how will it be undertaken, and how will it be enforced if legally binding If the system is flexible enough to allow for the inclusion of new POPs or other POPs If training and awareness‐raising is a component of the system described

7. 7 Labelling systems for products and articles Types of systems analysed: Section 2 – Systems to avoid the use of POPs in mixtures and articles Section 3 – Labelling systems for POPs as such and in mixtures Section 4 – Labelling systems for chemicals in articles Section 5 – Labelling system for chemicals in a national inventory

8. 8 Systems to avoid the use of POPs in mixtures and articles EU restriction on the use of hazardous substances (RoHS ) Legally binding system for new electrical and electronic equipment manufactured in the EU and imported into the EU Six substances including listed PBDEs are not allowed in more than 0,1 % in homogenous articles Articles that are in conformity with obligations of the RoHS directive are labelled with a “CE” mark

9. 9 Systems to avoid the use of POPs in mixtures and articles Joint industry guide (JIG) for material composition declaration for electronic products Voluntary system develop and applied by members of the Consumer Electronic association Suppliers report the presence of problematic substances above a threshold limit through a standardised material declaration for the whole supply chain, tool to enable to fulfill the EU RoHS obligations

10. 10 Ecolabels A voluntary national or supranational system to label the absence of certain chemicals in articles and products No international standardisation of labels, designed to protect environmental resources POPs free initiative of the Stockholm Convention Voluntary initiative to motivate industry to substitute POPs and to produce POPs free products Limits to define POPs free are set, the limits are analytically controlled Several alternatives are already on the market for BDE use (Paxymer TM ) and lindane use (LieMeister ® comb) Systems to avoid the use of POPs in mixtures and articles

11. 11 Labelling system for POPs as such and in mixtures The GHS Globally harmonised system for classification and labelling of hazardous (physical, health, environment) chemicals and mixtures, as all POPs are hazardous they are covered by the GHS To protect industry worker, farmer, consumer, emergency response workers, transport worker and the environment Implemented voluntary already by many countries, support for example by UNITAR, flexibility in implementation through block building approach while still promoting harmonisation Chemical name and CAS number hazardous chemicals in mixtures in concentrations above cut-off levels have to be given on the label California proposition 65 Legally binding in California (US), to inform citizens about chemicals in products, label not harmonised with the GHS

12. 12 Labelling systems for chemicals in articles Labelling of flame retardants in plastic materials used in articles, ISO 1043-4 (1999) Voluntary industrial guidelines harmonized worldwide Preventive system informing especially recyclers of the composition of the plastic based on specific markings on the materials Code markings apply to chemical contents ›1% for flame retardant (FR) 18

13. 13 Labelling systems for chemicals in articles Labelling requirements for certain articles containing crocidolite asbestos in the European Community Legally binding till 1999, then total ban of crocidolite Article marketed must be labelled if it contains crocidolite Articles are for example asbestos-cement pipes, acid and temperature-resisting seals, gaskets and gland packings Shape, size, format, and content of the label are mandatory

14. 14 Labelling system for chemicals in a national inventory The Stockholm Convention labelling of PCBs Legally binding system to keep track of appliances containing PCB identified in a national inventory through a label that indicates the presence of PCB More information on how to keep track on articles containing new POPs can be found in the: Guidance for the inventory of polybrominated diphenyl ethers (PBDEs) listed under the Stockholm Convention Guidance for the inventory of perfluorooctane sulfonic acid (PFOS) and related chemicals

15. 15 USE OF THE GUIDANCE

16. 16 Goods regulated by the Convention A listed POP as a chemical substance A mixture produced by intentionally adding a listed POP An article produced by intentionally adding a listed POP A non POP chemical that due to its production contains a listed POP unintentionally as a contaminant in a concentration higher than a trace contaminant: dicofol (with DDT) Other examples: A listed POP: DDT A POP mixture: Bayowet FT 248 liquid (50% solution with tetraethylammonium perfluoroctane sulfonate) A POPs article: acrylate and urethane polymers of N-ethyl perfluorooctane sulfonamidoethanol for carpet surface treatment

17. 17 Regulatory status of the new POPs (Annex A) Alpha hexachlorocyclohexane, beta hexachlorocyclohexane, chlordecone, hexabromobiphenyl, pentachlorobenzene: Total ban with production and use not allowed Commercial pentaBDE and octaBDE: Specific exemption for recycling of articles and use and final disposal of articles produced from such recycled articles Lindane: Production not allowed. Continuing use if registered as human health pharmaceutical for control of head lice and scabies as second line treatment Endosulfan: Production is allowed. Continuing use as a pesticide for a registered crop-pest complex

18. 18 Regulatory status of PFOS (Annex B) Listed in Annex B are PFOS, its salts and PFOSF. Also regulated are PFOS related chemicals, which are chemicals that contain the structural element PFOS in their molecular structure as they are and were produced with perfluorooctane sulfonic acid (PFOS), its salts and perfluorooctane sulfonyl fluoride (PFOSF) as an intermediate or starting material. Eliminate the production and use of PFOS, its salts, PFOSF and PFOS related chemicals as substances, in mixtures, and in articles containing these chemicals Specific exemptions and acceptable purposes are available for use and production of PFOS Examples are (specific exemptions) textiles and upholstery, coatings and coating additives or (acceptable purposes) photo- imaging, aviation hydraulic fluids

19. 19 Elements to consider in a labelling system What is the aim, objective, and content of the system? What will be labelled? How will the POPs be labelled (what information is on the label, for whom is it labelled, how is it done technically)? How can the system be enforced? What resources are needed for implementation by the producer, user, and government?

20. 20 Labelling and the supply chain Activities to avoid the use of POPs in mixtures and articles would be more efficient than labelling the presence of POPs Exporting Parties should either avoid the use of POPs during manufacture or implement a labelling system Importing Parties should implement the same labelling systems as the exporting Party, raise awareness held by the user, and enforce the labelling system A labelling system will allow the identification of POPs in mixtures and articles along the whole supply chain

21. 21 Analysis of the national situation Is your country a producer of POPs or an importer? What labelling systems are in place for chemicals, mixtures, and articles, and can they be adapted to include the new POPs? Has the GHS been implemented or is implementation planned, are the new POPs already classified and labelled, and is support needed to classify and label the new POPs? Does the country have the resources to develop and implement a national labelling system?

22. 22 Design and implementation of labelling system Adapt the system to the country needs and resources Considering the national economic situation, national human and environmental health issues caused by POPs, and the status of public awareness Ensure high level support Implement the system stepwise, easy to implement and efficient elements first, then determine medium and long term implementation goals Implement first on a provisional basis, if successful adapt then administrative and legal system Use the examples in Section 6.1 to 6.3 as a thought starter for your labelling system

23. 23 Checklist for classification and labelling approaches Which of the approaches outlined in this document are already implemented nationally? Which of the approaches adopted nationally are voluntary and which are regulated by legal instruments? Are there moves nationally to legalize any voluntary scheme? Are industrial chemicals, pesticides, and articles classified and labelled following the same approach (e.g. the GHS)?

24. 24 Which industries or manufacturers have adopted any voluntary POPs labelling? Has the RoHS directive been adopted on articles for sale and in use nationally, as well as implemented for export to the EU? If not, why not? What methods have been adopted for classification and labelling of specific or all uses of plastics? Have they been adopted for named POPs in articles that may be recycled? Checklist for classification and labelling approaches

25. 25 International harmonisation of labelliing schemes Consider harmonising the labelling systems for POPs at the international level using the COPs of the Stockholm Convention as a platform Consider to implement the GHS to cover all POPs for industrial chemicals and pesticides Considering involving through the COP the GHS Sub Committee for GHS of UNECE in harmonising labelling of POPs and cut off levels of POPs in mixtures A labelling system for articles and their plastic components could be recommended by the COP to be used voluntarily by industry Industry could be encouraged to apply the POPs free initiative to more chemical products and articles

26. 26 Thank you! For more information, please contact: Secretariat of the Stockholm Convention 11-13, Chemin des Anémones - 1219 Châtelaine, Switzerland Tel.: +41 (0)22 917 8729 - Fax: +41 (0)22 917 8098 E-mail: ssc@pops.int, Website: www.pops.intssc@pops.intwww.pops.int