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REACH 

coatings, inks & artists' colours manufacture and application

 

This page provides information on the following topics: 

 

 
One fundamental aim of the REACH Regulation is to ensure all uses are safe to man and to the environment.  
Within REACH, “use” is defined in a specific and unique way. Established means of describing use are no longer appropriate for communicating, up and down supply chains, information relating to use. A new ECHA system has to be employed to enable “use” to be described in accordance with the REACH definition.
 
With the aim of helping manufacturers and importers of substances understand how substances typically are handled in the manufacture of coatings, printing inks and artists’ colours, and in their application in industrial processes, by professional users and by consumers, CEPE has compiled descriptors of use covering all these use situations.
 
More information can be found in the attached Information Note, on the use descriptor scheme; on manufacturing and application processes; and how the descriptor of use tables can be used by upstream suppliers, by coatings and inks manufacturers, and by downstream users. 

CEPE has aimed to identify a set of standard descriptors of use that cover all coatings, inks and artists' colours manufacturing and application processes. In the interests of harmonisation and consistency, manufacturers and importers are urged to adopt relevant uses from the CEPE tables as identified uses. CEPE communicated information on these tables to major raw material organisations on 2 June 2009. Both manufacturers and downstream users are encouraged to select use descriptors from the CEPE tables and to communicate these up and downstream, when required.

Please note that, in addition to these standard descriptors of use, individual CEPE member companies may communicate, up their supply chains, any specific uses that are not included in the tables. 

The six descriptor of use tables can be accessed on the following links:
 

These tables have been updated to teflect revisions to PC5 and PC9, as introduced in Version 2 of ECHA guidance R12 (published March 2010).

 

 
REACH requires manufacturers and importers to carry out a risk assessment for each use of a hazardous (dangerous) substance, which is manufactured in quantities of 10 tonnes or more per annum, and to identify the risk management measures to ensure each use is safe to man and/or the environment.
CEPE has established typical worst case operating conditions for each use identified in the descriptor of use tables. These are intended to help manufacturers and importers use, in occupational or consumer health risk assessments tools, those operating conditions that are applicable to the manufacture and application of coatings, inks and artists’ colours.
To further help manufacturers and importers identify risk management measures appropriate to the manufacture and application of coatings, inks and artists’ colours, CEPE has identified best practice risk management measures for each use identified in the descriptor of use tables.
 
The extended descriptor of use-operating condition-risk management measure tables are currently available and can be accessed on the following links: 

These tables have been updated to teflect revisions to PC5 and PC9, as introduced in Version 2 of ECHA guidance R12 (published March 2010).

 

Specific emission release categories (SpERCs) for the manufacture of coatings, inks and artists’ colours 

CEPE has prepared SpERCs for the majority of products manufactured by CEPE members. These are intended to help manufacturers and importers use, in environmental risk assessments tools, typical worst releases from manufacturing processes to the three environmental compartments.

The SpERCs are currently available and can be accessed on the following links
The information in these SpERCs has been uploaded into the environmental section of the ECETOC TRA tool. They form part of the set of sector-specific emission factors, for use by manufacturers and importers of substances in the preparation of environmental risk assessments. They also are available in overview format on CEFIC’s REACH website, via either of the following links:
and, once downloaded, by clicking on the “coatings and inks” tab.
CEPE has adopted the basic principle that SpERCs for the application of coatings and inks are most appropriately developed by industry organisations representing users of coatings and inks. The only exception to this rule is that where there is no representative or active organisation for a particular user sector, CEPE will prepare relevant SpERCs.
·         An overview of the currently available SpERCs for application of coatings and inks can be found on CEFIC’s REACH website, via either of the following links:http://cefic.org/templates/shwPublications.asp?HID=750&T=806
http://cefic.org/en/reach-for-industries-libraries.html and, once downloaded, by clicking on the “coatings and inks” tab.The information in these SpERCs has been uploaded into the environmental section of the ECETOC TRA tool. They form part of the set of sector-specific emission factors, for use by manufacturers and importers of substances in the preparation of environmental risk assessments.
Please note that further SpERCs covering application of coatings and inks are likely to be developed and added to this table.

 

 
Introduction.
 
See: ECHA Guidance on information requirements and chemical safety assessment Chapter R.12: use descriptor system. Draft revision, dated 7 November 2009.

A chemical safety assessment (CSA) shall cover not only the uses of a substance, but also the subsequent life cycle stages of substances incorporated into or onto an article matrix. The manufacturer or importer of such substance may find it necessary to specify which types of articles are covered in the CSA and the Exposure Scenarios.

If a substance is not expected to be included into articles during use, no article category is to be assigned (e.g. solvents).  
 
The ECHA guidance referred to above provides guidance on different categories of ACs, and how and when they are to be allocated.
 
Article categories for coated or printed articles
 
NOTE: in practice, ACs will be of limited relevance to coating films or print on articles (which are produced by the application of coatings and inks to the article concerned). ACs are only included in risk assessments where there is a release of a dangerous substance from the article. Few dangerous substances will be found in applied films; and the applied films are not intended to be released during the article use cycle. It is also highly unlikely that once incorporated in an article, any dangerous substances will exceed the threshold of 0.1%.
 
Coating films and print are found on very many articles, which are produced from a variety of materials with many different purposes, end uses and users. CEPE does not have a comprehensive understanding of all service life stages of coating films and  print (and, by analogy, of substances present in the applied films. We therefore are unable to provide any detailed information on the ACs applicable to particular substances. The best we currently can advise is that all ACs potentially are applicable to the professional and industrial application of coatings or inks. 

As an aid to manufacturers and importers we have annotated here below the AC tables contained in the ECHA guide with information on which are applicable to CEPE members’ products:

Review of earlier CEPE recommendation. 

The use descriptor tables published by CEPE do not contain any ACs. An article is produced from a number of components, of which the coating film or print is invariably a minor part. It would be presumptuous for suppliers of just one component to allocate an AC to an article. In CEPE’s view, only producers of articles can decide the ACs applicable to their products.
 
Accordingly, the CEPE tables covering industrial and professional application of coatings and inks, had indicated “DU applicators to complete” in relation to ACs.
 
Only limited data on ACs has been received from the downstream use chain. In the light of this situation CEPE has reviewed its earlier decision and now annotates the AC tables contained in the ECHA draft guidance.
 

Update : 28 April 2010

Date Details
April 2009
Original webpage issued:
  • Descriptor of Use (DoU) tables
  • Information Note on manufacture and application of coatings and inks and CEPE process for preparation of DoU tables
January 2010
Page extended with information on:
  • Operating Conditions and Risk Management Tables
  • Guidance on Article Codes (ACs) for coated and printed materials
  • Statement on ACs in DoU tables
February 2010
Page extended with information on:
  • Statement on action CEPE members may take to  notify specific uses (uses not covered by the CEPE DoU tables)
  • Specific Emission Release Categories (SpERCs) for coatings and inks manufacturing processes
  • Updating of DoU-OC-RMM tables for manufacture of coatings and inks with SpERC references
  • Editorial corrections
April 2010
Page extended with information on:
·         DoU and DoU-OC-RMM tables amended to replace references to PC5 and PC9 by PC9a, 9b, 9c, as relevant (following publication of revision of ECHA guidance R12, March 2010).
·         Specific Emission Release Categories (SpERCs) for the application of coatings and inks.
Availability of manufacturing and application SpERCs on the CEFIC website and inclusion of industry emission factors in the ECETOC TRA tool.
 

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