AGROCHEMICALS field a little bit ”. In general terms , however , he was not optimistic about regulatory harmonisation . The EC , the European Parliament and the Council are all going in the same direction on this issue , albeit with different wordings , so the export ban will take place , Oger added . Many questions still unanswered making the impact difficult to evaluate in terms of the exact scope , the definition of ‘ ban ’ and the legislative vehicle used . The proposed restrictions on all per- and polyfluoroalkyl compounds ( PFAS ) is mentioned in the CSS but is being led by five MS who will submit proposals to ECHA in 2022 . Their proposed definitions , however , differ from the OECD ’ s and this could potentially restrict wide areas of fluorine chemistry .
Mixture of challenges
Last but not least , the CSS concept of ‘ mixture assessment factors ’ will be introduced in a REACH revision “ to ensure the risks from simultaneous exposure to multiple chemicals are effectively and systematically taken into account ”. This , said Oger , would have a direct impact on co-formulants in crop protection products . “ This is a very blunt instrument . It does not allow any kind of refinement and is something we are not used to in pesticide evaluation .” There would certainly be a negative impact on the availability of products as a result . A final priority and a more important one in the short-term is the introduction of new hazard classes into the Classification & Labelling Regulation that are not based on adverse effects but on MoAs or properties , i . e . endocrine disruption , PBT , vPvB , PMT and vPvM . The EC is expected to come forward with a proposal in early 2022 . “ It goes against the core principle of the GHS and the CLP regulation , but it was a known consequence of having a hazard-based approach in the EU ,” Oger said . And the potential impacts are “ frightening ” if the EC tries to push it on a global level in ways that others may not accept , leading to discrepancies between the EU system and the global system . Other relevant elements in the CSS include the ‘ One substance , one assessment ’ concept . This stipulates that when an assessment is proposed under one piece of legislation , full account shall be taken of the planning under other pieces of legislation , so that coordinated action is ensured , leaving open the question ‘ Who does what ?’ Finally , a potential reopening of REACH through targeted amendments to REACH and sectoral legislation , based on key findings from its practical implementation , could hit crop protection too . The main impact would be on co-formulants in plant protection products . •
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Maggie Saykali
EFCG msa @ cefic . be
www . cfcg . cefic . org
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