1. CARACAL 12 13-14 March 2013 valentina.bertato@ec.europa.eu
COM Project – “The potential impact on industrial competitiveness of restrictions on certain CMR 1A and 1B substances in articles”
CARACAL 12
13-14 March 2013

2. Background for the project
REACH foresees a specific restriction procedure under art. 68(2):
COM proposal
No involvement of RAC and SEAC
It may apply to CMR cat. 1A and 1B in articles that could be used by consumers
This procedure is proposed by COM for the first time to restrict 8 PAHs that can be found in consumers' articles
COM and MS believe that there is a need for criteria on how to apply art. 68(2)
Before formulating the criteria: building experience on a concrete group of substances

3. Status and timeline of the project
A contract with ICF International was signed in December 2012
The kick-off meeting took place in January 2013
The Commission, in collaboration with ECHA, prepared a list of 44 CMRs 1A-1B potentially present in articles
From this list, a shorter list of substances will be defined for a more detailed analysis
The final report is due by November 2013

4. The "starting" list of CMR 1A-1B substances
On the basis of the outcome of ECHA project, and of further considerations, 44 substances were selected.
The substances have been divided into 3 groups:
1st group: substances on which to focus; these are substances more likely to be found in consumers articles
2nd group: substances on which the presence in articles needs to be confirmed in the first part of the study
3rd group: substances already in Annex XIV

5. Groups of substances in the study
Substances more likely to be in consumers' articles
Some substances in candidate list and considered/proposed for prioritisation by ECHA
Phthalates, mostly not registered (concern: presence in imported articles)
Some "newly classified" CMRs or substances under discussion for future classification
Monomers that could be present in final articles
Substances for which presence in consumers' articles needs to be checked
Substances already in Annex XIV: to investigate presence in imported articles

6. Data to be collected on the "starting" list
Articles in which the substance might be present
Market information for the articles (volume, value of the market, EU production, import/export)
Market players
Identification and initial assessment of alternatives
Potential for consumers' exposure (to help selection of substances for the 2nd part of the project)
On the second group of substances, data should be collected only if there is evidence of presence in articles

7. The questionnaire for data collection
ICF sent a questionnaire to stakeholders to collect the data needed for the first part of the study
Deadline is end of March
More detailed information will be collected via ad-hoc consultation of some stakeholders
Please transmit the questionnaire to organisations/individual companies that might provide useful information

8. Second part of the project
On the basis of the information collected in the first part of the project, the Commission, with the collaboration of ECHA, will select some substances:
Presence in articles and economic importance of the substance
Possible exposure to consumers
Socio-economic aspects will be investigated:
Impact of a possible restriction on main actors: manufacturers (substances and articles), formulators, users, consumers
Impact in the EU and/or in relation to third countries
Cost/benefit analysis
Social impacts (loss/gain of jobs)

9. Expected outcome of the project
The main objective of the project is to gather experience on practical examples and suggest criteria for identifying substances for a restriction procedure following art. 68(2)
Which information could indicate if a substance is or isn't a good candidate for this procedure?
Information on exposure and socio-economic impact?
The criteria proposed by the consultant will be used by COM as a thought starter

10. CARACAL involvement
Presentation of the results of the project in November CARACAL
Consultation of CARACAL when elaborating on the criteria?
Any comment/suggestion?