According to an item in the August 10, 2022, ECHA Weekly, France, Ireland, and Germany are requesting interested parties to submit information related to skin sensitizing substances in consumer mixtures. The European Chemicals Agency (ECHA) website states that this is an opportunity for all sectors to provide information on the presence of skin sensitizing substances in mixtures with consumer uses, including information on known safe uses. The call for evidence is issued to assess whether there are risks that are adequately controlled under specific conditions and what impact additional regulatory risk management would have on society. The scope of the investigation comprises substances fulfilling the criteria for classification as skin sensitizers as defined by Regulation (EC) No 1272/2008 on the classification, labeling, and packaging of substances and mixtures (CLP Regulation) in mixtures marketed or available for consumers in the European Union (EU)/European Economic Area (EEA). Uses of substances in cosmetic products are outside the scope of the investigation. The deadline for comments is September 30, 2022.
The objective of the call for evidence is to obtain information on:
- The sectors and types of uses/applications concerned;
- Measures currently in place (g., changed formulation, reduction of concentration, specific packaging, conditions of use) to minimize consumer exposure;
- Experience regarding substitution efforts, availability, and costs of alternatives or reasons for non-substitution;
- The potency of the skin sensitizing substances and their technical functions in the mixtures;
- Safe use of consumer products;
- Epidemiology of allergic contact dermatitis and other health-related information, including health costs; and
- Analytical methods to detect the presence of skin sensitizing substances in mixtures.
The target groups are:
- Companies (g., manufacturers, formulators, suppliers, distributors, and importers) and their associations;
- Trade associations;
- Member state authorities; and
- Any other stakeholder (including consumer associations and health insurance organizations) holding relevant information.
ECHA notes that calls for comments and evidence allow interested parties to signal their interest and express their views and concerns in the preparatory phase of the restriction proposal. They also let interested parties comment on the different documents under preparation in relation to restrictions, such as reports on substances in articles and guidelines on restriction entries. Calls for comments and evidence do not take the place of public consultations on restriction proposals developed by EU member states or ECHA, which form a standard part of the restriction process.