REACH & CLP
reach regulation
The REACH Regulation lays down the rules for the Registration, Evaluation, Authorisation and restriction of Chemical substances in the EU. It entered into force in June 2007 with a first registration deadline by 1 December 2010. General information on REACH and the ceramic industry can be found on the Cerame-Unie REACH webpage.
In early 2007, PRE set up a REACH Working Group (WG) in order to assist refractory companies with the implementation of the REACH Regulation. Regular meetings were held in Brussels and detailed discussions took place to develop a common understanding and to improve the communication throughout the supply chain. In 2008, PRE co-financed an online substance inventory database for refractory substances in which almost 50 companies participated. In 2009 and 2010, discussions focused on the registration dossiers and exposure scenarios and PRE developed a generic use description for the refractory industry. The PRE REACH WG also tackles REACH related legislation such as the Classification, Labelling and Packaging Regulation.
The Technical Implications of REACH in the refractories industry were presented in Madrid at the REACH Seminar, organised in conjunction with the 50th annual congress of the Spanish Ceramic and Glass society on 26 October 2010.
(Zirconia) Aluminosilicate Refractory Ceramic Fibres (RCF)
In August 2009, it was proposed that certain types of RCF be added to the REACH Candidate list of Substances of Very High Concern. In August 2011, two additional types of RCF were proposed. On both occasions PRE submitted detailed comments during the public consultation. For the reasons expressed in the Facts and Consequences document, PRE is of the firm opinion that RCF should not be prioritised for authorisation.
On 24 June 2013 ECHA published its fifth draft recommendation for inclusion of substances in Annex XIV, including RCF. Further information can be obtained from the PRE secretariat or on the website of ECFIA, representing the High Temperature Insulation Wool industry.
A joint industry position paper explaining why a REACH authorisation is not the appropriate way forward for RCF can be found here (in English, French and German).
Classification and labelling of silica monolithics
The CLP Regulation (EC 1272/2008) on classification, labelling and packaging, entered into force on 20 January 2009. It replaces the Dangerous Substances Directive (67/548/EEC) and the Dangerous Preparations Directive (1999/45/EC). It introduces new classification criteria, hazard symbols and labelling phrases.
A series of meetings on Respirable Crystalline Silica (RCS) and internal and external measurements of the level of RCS in the range of products have been organised in 2010-2011 by a number of PRE member companies. These measurements resulted in the classification and labelling as Stot RE 2 (Specific Target Organ Toxicity - Repeated Exposure, Category 2).
Classification and labelling changes for mixtures need to be introduced no later than 1 June 2015. Some companies may voluntarily choose to introduce these changes earlier if they wish. Further information can be found in the first PRE position paper (2012) focusing on silica monolithics and the second PRE position paper (2015) focusing on all refractory monolithics.
RAW MATERIALS
critical for the refractory industry
The European refractories industry is vital for European industry as a whole, but is heavily dependent on imports of refractory industrial minerals. The supply situation for the European refractory industry is particularly critical for high grade magnesia, bauxite and graphite which are mainly sourced from China due its vast raw material reserves.
PRE has therefore followed with great interest the work of the European Commission ad-hoc group mandated to define a list of critical raw materials. This action was the first of ten action points identified under the European Commission's Raw Material Initiative. The first criticality report, published in June 2010, identifies 14 raw materials as critical, including graphite, taking into account their supply risk and economic importance. Magnesite and bauxite are identified as potentially critical. Annex V of the report includes detailed qualitative information on all assessed raw materials. A 2013 criticality report confirms 13 of the 14 raw materials identified in 2010 (tantalum is excluded due to a lower supply risk) and adds six new materials: borates, chromium, coking coal, magnesite, phosphate rock and silicon metal.
Further information can be found in the PRE document entitled Refractory Ceramics and Industrial Minerals are Critical for European Industry (2009).
A presentation on the importance of raw materials for the European Refractory Industry was also made at the European Parliament Ceramics Forum on 17 November 2010.
General information on the raw materials initiative can be found on the Cerame-Unie raw materials webpage.
WTO dispute settlement Panel
China applies a range of export restrictions on raw materials such as export duties, export quota and non-automatic export licensing. PRE and Cerame-Unie strongly support the WTO Panel proceedings on Chinese export restrictions on raw materials as requested by the EU (and by the US and Mexico) on 9 November 2009. An overview of the case can be found here.
The Panel report was circulated on 5 July 2011. The WTO Panel found that China's export restrictions were not justified on environmental grounds and should be removed. China informed the WTO Dispute Settlement Body of its intentions to implement the recommendations and rulings within a reasonable period of time.