The Backstory
On January 30th, the European Chemicals Agency (ECHA) published its proposal to restrict the placement of microplastics on the EU market, either via manufacturing or import, and whether those microplastics exist in pure form or in mixtures above 0.01% by weight. Several derogations from the restriction are available in Table 19 of the restriction report, depending on how the product is used and disposed; whether the microplastics are naturally occurring polymers, biodegradable, or present in a dissolved form, for example.
What’s Changing
Even if your product is fortunate enough to receive a derogation from the actual restriction or ban of microplastics, if it contains particles or fibers that meet ECHA’s definition of a microplastic, you may still have an obligation to “provide relevant instructions for use to avoid releases of microplastics to the environment, including at the waste life-cycle stage,” in addition to the obligation to report to ECHA the annual volumes and exposures to the environment by January 31st each year.
Implications
So how does this affect your Safety Data Sheets (SDS)? ECHA have proposed that the “relevant instructions for use to avoid releases of microplastics to the environment” be listed, amongst other places, on the product label and/or SDS (Annex XV Restriction Report, Table 3, clause 7).
If you make or sell products that may be affected by ECHA’s recent restriction proposal, you must realize that even if you’re off-the-hook on the restriction itself, you may still have obligations that require you to update your SDS and labels.
Whether you need help with software driven SDS authoring solutions, or complying with ever-changing hazard communication and global chemical legislation requirements, Global Safety Management and its team of experts is here to help. Questions? Contact us today!
