Additional REACH restrictions for D4 and D5 are premature and unjustified
Brussels, 12 June 2017 – The REACH restriction concerning the use of octamethylcyclotetrasiloxane (D4) and decamethylcyclopentasiloxane (D5) in wash-off personal care products should be fully implemented and its effectiveness evaluated before any new regulatory proposal is made. Given the extremely low levels of D4 and D5 that have been measured in surface waters, any additional restriction would be unlikely to result in any measurable environmental benefits.
The silicones industry considers that the restriction project concerning the use of D4 and D5 in leave on cosmetics and other consumer and professional products (e.g. dry cleaning, waxes and polishes, washing and cleaning products) is premature and unjustified.
Commenting on the publication of the restriction intention, CES-Silicones Europe Secretary General Dr. Pierre Germain said, “We believe that the recent conclusions reached by the Committees of the European Chemicals Agency (ECHA)1 do not warrant additional regulatory action.”
He added: “We remain committed to working with ECHA and other stakeholders throughout the restriction process to ensure that any future decisions are based on the most recent and robust scientific and socio-economic evidence”.
In the course of their detailed assessment of D4 and D5 under REACH, the UK authorities conducted an in-depth review and analysis of all available Risk Management Options (RMOA), and concluded that a restriction of D4 and D5 in wash-off personal care products is targeted and proportionate. Although the silicones industry continues to believe that the scientific evidence demonstrates that D4 and D5 do not pose a risk to the environment in their current uses, it is committed to active participation during the implementation of this restriction.
ECHA’s Committees agreed to focus on wash-off personal care products
In their final opinion2 in June 2016, ECHA’s Risk Assessment (RAC) and Socio Economic Assessment (SEAC) Committees agreed with the UK’s proposal to restrict D4 and D5 only when used in wash-off personal care products as the main source of emissions to the aquatic environment. This conclusion was reached after an in-depth assessment that included an evaluation of the effectiveness and proportionality of the measure.
Environmental monitoring to assess the REACH restriction’s effectiveness in reducing aquatic emissions should be conducted before any new measure is proposed.
ECHA’s Committees agreed that environmental monitoring activities would help check the effectiveness of this restriction. They proposed that a review of this restriction should be done latest after five years considering its effectiveness with respect to emission reduction. The outcome of the environmental monitoring should help provide sufficient information to assess whether further regulatory measures are needed.
Against this background, the silicones industry considers that the new restriction project is premature, unjustified, and would not likely result in any environmental improvements. In addition, it is inconsistent with the ECHA Opinions. The silicones industry is nevertheless committed to working with ECHA and all relevant stakeholders throughout discussions regarding the need for new restrictions.
About cyclosiloxanes D4 and D5: D4 and D5 are cyclosiloxanes, basic members of the broad family of silicone materials. D4 and D5 are two cyclosiloxanes in commercial production and their use has been proven safe for human health and the environment.
About CES – Silicones Europe: We are a non-profit trade organisation representing all major producers of silicones, silanes and siloxanes in Europe. CES is a sector group of the European Chemical Industry Council (CEFIC), which is both the forum and voice of the European chemicals industry. We provide health, safety and environmental information on silicones and are dedicated to the principles of Responsible Care. For more information, visit www.silicones.eu and follow us on Twitter @siliconesEU
2 RAC and SEAC opinion on Annex XV restriction report https://echa.europa.eu/documents/10162/7209f47e-58a0-4fa7-989011366f5aa4e9