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no clear EU guidance has been given for
the use of multilayer leaflets, leading to
various interpretations of national
authorities- this is something we are
questioning the Commission about.
REACH
At the time of writing, the 2nd
REACH registration deadline is weeks
away. Companies manufacturing or
importing chemical substances in the
EU will have to complete Technical
Dossiers to be allowed to market
these chemicals. However, REACH
has far wider implications, which can
also directly impact FINAT members.
In particular, the need to check if
products contain Substances of Very
High Concern, and the obligation to
implement any Risk Management
Measures laid out in the new
extended Safety Data Sheets are two
items I would like to draw your
attention to.
FINAT has closely monitored
developments in guidance and
enforcement of REACH as a member
of the CheMI platform, the platform
for downstream users of chemicals in
manufacturing industries. FINAT has
been actively involved with the
review of REACH regulation, giving
input to a number of studies that
were undertaken by the European
Commission. In the end, the review
ISO
TECHNICAL
SPECIFICATION
FOR
LABELS
An ISOWork Item Proposal has been
submitted to start work on a technical
specification for labels. FINAT and
representatives of the other national
label associations have participated in a
teleconference with the Swedish
Standards Institute and the initiators of
this proposal (Ericsson and Ikea) to
discuss this early 2013. The idea behind
the proposal is to establish a harmonized
framework for questions to be asked to
label converters when ordering labels.
Having explained their reservations
concerning a possible ‘one size fits all’
specification, FINAT and the other
associations were explained this is not
the intention of the proposal and that
existing material would be taken into
account as much as possible. Clearly this
will be a topic that we will be following
closely, via the national standards bodies,
industry representatives from national
label associations and FINAT will be
proposed as member of the working
group involved.
did not lead to any significant changes
in the regulation, except for
adjustment of the fees for registrants.
Having attended the last Lead
Registrant Workshop in Helsinki,
FINAT has conveyed the most
up-to-date guidance to its members.
BIOCIDES
REGULATION
CheMI has been particularly active is
in the biocides regulation, which will
come into force in September 2013.
This regulation will replace the old
biocides directive, and amongst
others, will have a different definition
and requirements for articles treated
with biocides. This is of relevance to
our members, especially as treated
articles had a very vague description
and no cut-off limits in the draft
guidance. This meant that even the
tiniest amount of a biocide (which for
example can be used in adhesives)
would automatically result in an
article falling under the regulation.
As a platform we have been very vocal
in biocidal stakeholder meetings to
have the definition changed and
scope clarified. At the moment, a new
draft has been circulated, and while
not all of our concerns have been
addressed, we do see improvement.
We will attend the Biocidal
stakeholder day in July 2013 to obtain
further updates.
Nilpeter A/S
• Elmedalsvej 20-22 • DK-4200, Slagelse • Denmark • Phone: +45 5850 1166 • Fax: +45 5850 5060 • e -mail: nilpeter@nilpeter.com
See more at nilpeter.com
Be on the safe side
in your future choice
of
production environment.
Experience it first-hand
in our
Technology Centers.
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