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BCF calls for further changes to UK REACH after small step in the right direction

The British Coatings Federation has welcomed recent proposed changes to the forthcoming UK REACH regime as a small but welcome step in the right direction. However, it has also warned that these changes alone will not be enough to prevent the coatings sector – and wider chemicals industry – from being hit hard financially under the new post-Brexit regime. This is because it does still not resolve the underlying, inherent problems with the proposed UK REACH system namely duplication of the EU REACH system and re-registration of all substances in a new database. It is this wholesale re-registration – including full data dossiers duplicating registrations already held in the EU REACH system – which will prove so bureaucratic, burdensome, and costly to business.

The easiest and seemingly best way to avoid this wholesale duplication would be for the UK and EU to negotiate a data-sharing agreement as part of the ongoing Free Trade Agreement talks. This would potentially mean the UK regulator would maintain access to data already registered in the EU REACH database and avoid it having to be re-registered in the new UK REACH system. The BCF fully supports the UK Government’s attempts to achieve this result as part of the FTA talks.

However, if that data-sharing outcome is not achieved as part of an FTA, the Government needs to go further and initiate greater changes to the proposed UK REACH system. The time extension for substance registrations simply spreads the cost of the registration requirements over a longer period: it does not reduce the overall cost to business. Those additional costs will still make it uneconomic for some lower quantity substances to be registered in the UK REACH database, making them unavailable in the UK and leaving UK companies at a significant disadvantage to their EU counterparts. Alternatively, UK businesses will have to take on the registration costs themselves to maintain access to crucial substances, again putting them at a competitive disadvantage.

Tom Bowtell, CEO of the British Coatings Federation said:

“Along with others we have been actively and positively engaged in conversations with the UK Government for well over a year. It is good to see that the Government has listened to the genuine concerns industry has raised and amended their plans for UK REACH. However, while we welcome the changes as a step in the right direction, sadly we do not believe the scale of the amendments are enough to offset the large costs and inconveniences UK business will suffer at the hands of UK REACH system as it stands.

“We hope that a data-sharing agreement on chemicals can be negotiated between the UK and EU as part of an FTA, and fully support the Government as it continues to work for that outcome: it would seem to be the most practical solution to this problem. However, if such an agreement does not come to pass then we hope the Government will continue to engage with, and listen to, the continued concerns of industry. Ultimately, we hope they realise we are not crying wolf over the impact of UK REACH on companies using chemicals like the paint, coatings and printing ink industries, and agree to make further amendments to their plans that will mitigate the effect of the new UK regulatory system on business.”

BCF gives evidence on UK REACH to House of Lords Committee

British Coatings Federation Ltd
Westwood Way, Westwood Business Park Coventry
CV4 8HS
www.coatings.org.uk
info@bcf.co.uk
Registered in England 745398

On the 7th of October 2020 Tom Bowtell, CEO of the British Coatings Federation gave evidence to the House of Lords EU Environment Sub-Committee on the subject of Government plans for UK REACH.
In his comments to the Committee he explained to Peers how UK REACH, as currently configured, will significantly and negatively impact on the coatings and printing inks sector, as well as the chemicals industry more widely.

His evidence stressed that if the UK Government fails to negotiate data-sharing as part of a chemicals annexe to the EU Free Trade Agreement, the resulting need to register chemical substances into a separate UK REACH database will cost industry over £1 billion. This would put UK Coatings manufacturing – and sectors further downstream like automotive and aerospace that its members supply – at a significant competitive disadvantage to their EU competitors.

During the Committee evidence session Tom also:

• Highlighted the risk of the UK losing Foreign Direct Investment if it is no longer an attractive place to manufacturer chemical-based products like coatings; • Expressed concern that the extra bureaucracy and cost of a mirrored UK REACH system will have a significant impact on business, especially smaller companies and downstream users who have not had to engage with EU REACH on registrations before now; • Welcomed plans to extend the registration period for substances into UK REACH from two to up to six years as a step in the right direction. However, while this measure is of some help it does not solve the underlying problems of a duplicate REACH regime. He therefore called on the Government to think again about the structure of UK REACH from 1st January 2021 if it cannot negotiate data-sharing as part of an FTA; • Reiterated a major worry of BCF members that, even with an extended registration period, many small volume substances might be deemed economically unviable to register in UK REACH due to the fact the UK is ten times smaller than the EU market. This could mean these small volume substances being lost to UK manufacturers entirely; • Drew attention to Chemical Watch’s recent survey on that subject which reported that 27% of EU companies and 7% of UK companies were considering not re-registering substances in UK REACH due to cost or complexity; • Pointed out that the proposed fee structure for UK REACH registration is the same as that for EU REACH, even though the UK market is 10 times smaller than that of the EU. If fees are to be levied for registrations into UK REACH they should be more proportionate to the size of the market; • Bought to the Peers’ attention that industry is still awaiting detailed guidance on UK REACH to be published by the Government, leaving businesses with little time to truly get to grips with new regulations;
British Coatings Federation Ltd Westwood Way, Westwood Business Park Coventry, CV4 8HS www.coatings.org.uk info@bcf.co.uk Registered in England 745398

• And asked whether the Government will publish its economic and environmental impact assessments for UK REACH to allow for more comprehensive debate on the subject.

Commenting on the evidence session, Tom Bowtell said:

“I was grateful to be able to give evidence to the House of Lords. It was an important opportunity to make sure the Committee Members understood how UK REACH is going to impact on downstream users of chemicals in the UK – like the coatings and printing inks sector – as well as on the chemicals industry more widely. Additional costs and reduced availability of substances from which to manufacture are going to be genuine consequences of the current plans for the UKs new chemicals regime. We therefore urged the Committee to prompt the Government to publish its economic impact assessment of its plans for UK REACH so that we can see what assumptions it is making its decisions upon.

“With the clock ticking down until the Brexit Transition Period ends the UK Government needs to recognise that – unless data-sharing with the EU can be agreed as part of an FTA – the way UK REACH is currently configured will hit industry hard. There is a real risk the extra regulatory burden will lead to a reduction in foreign direct investment to the UK: moreover, the extra costs and added bureaucracy will hit SMEs and downstream users like those in the coatings and printing inks sectors particularly heavily. We need to see more radical changes made to UK REACH – beyond the extension to registration periods already agreed – to mitigate the effects on business.”

British Coatings Federation announces new President at virtual Board meeting

Outgoing British Coatings Federation President David Beckford of Pronto Industrial Paints handed over the presidency to Guy Williams, Chief Executive of U-POL at BCF’s virtual board meeting on the 5th of October 2020.

Commenting on his appointment, Guy Williams said that he was looking forward to serving the for the next two years and supporting the BCF team.

“I would like to personally thank David for his fantastic leadership throughout his presidency which must be one of the most turbulent periods in BCF’s history. Looking forward, the BCF, like many others, will face significant challenges ahead. However, the BCF is well placed to weather the impacts of Covid-19 and is continuing to lobby hard on other issues with the EU Free Trade Agreement and UK REACH top of the current priorities.”

Whilst Presidents typically serve two-year terms, outgoing President Beckford had been asked to stay on for an extended period due to Covid-19. Speaking of his time as President, David thanked the Board and said it had been an honour to serve the industry.

“BCF has developed considerably over the last 10 years, and I have no doubt it will continue to grow and thrive. Looking back, I take immense pride in the achievements of BCF in recent years. Starting with the new HQ in Coventry, we’ve seen the Federation strengthen significantly and has twice been named Trade Association of the Year. Financially we are on a very sound footing now and Corporate Governance is exemplary, with high engagement at Board Level and a clear strategy for the years ahead.”

Tom Bowtell, BCF’s Chief Executive commented:

“It was been a pleasure to work alongside David Beckford for the last two and a half years. During his tenure David has dealt with a number of major challenges facing both the industry and wider society. I am looking forward to working with Guy Williams as we continue to support our members and the industry into the future.”

Coatings Care Awards finalists announced by the BCF

British Coatings Federation (BCF) announces finalists for Coatings Care, a voluntary programme which provides an opportunity for members to benchmark their environmental performance against 45 KPIs. For additional details on the programme and why this initiative is important, click here.

The Coatings Care Overall Best Performer Award is presented to the company that has demonstrated best in class performance across a range of key performance indicators, including VOC emissions, energy consumption, waste and recycling, and accident and incident statistics.

Our shortlisted companies for this award are:

  • AkzoNobel Decorative Paints (Ashington)
  • AkzoNobel Industrial Coatings (Deeside)
  • Pronto Industrial Paints (Chesterfield)
  • Pulse Printing Products (Bristol)
  • Teal & Mackrill Ltd (Hull)

The Coatings Care Progress Award is presented to the company that has made the most significant year on year improvement in its performance on the same health, safety and environmental criteria.

Our shortlisted companies for this award are:

  • Crown (Darwen)
  • Dacrylate (Kirkby-in-Ashfield)
  • Rustins
  • Steyport (Blackburn)
  • Sun Chemical

 

Tom Bowtell, BCF Chief Executive commented “The programme is a great way for member companies to compare and understand their relative environmental performance and look for ways to continuously improve. Well done to the finalists of our awards and I look forward to announcing the winners on the 6th of November.”

Creating a network of coatings industry ambassadors to engage with schools and universities

The British Coatings Federation has partnered with the Surface Coatings Group of the Royal Society of Chemistry (rsc.li/surfacecoatings) and PRA (https://www.pra-world.com/) to create a national network of ambassadors for the coatings industry, with the training delivered by Cogent Skills.

Our goal is to equip Coatings Ambassadors with the skills and materials to run sessions at schools and universities, to explain the contribution the industry makes to the economy and society, as well as the varied roles and opportunities within it.

Following two successful events at the end of 2019, July saw the first virtual Coatings Ambassador training, with a diverse group of attendees from AkzoNobel, BASF, Dacrylate, Imerys, Manchester University and Venator and had an international flavour with delegates joining from Brazil and the USA.

Through our ambassador programme and the Coatings Careers Hub, our online forum with vacancies and career resources, we are hopeful that we can encourage the next generation to see the world of opportunities in our industry.

We would like to thank both the companies and individuals who took part and who are now part of an important and growing network. Whilst there is currently a shortage of skilled staff and an ageing workforce, we hope that the Coatings Ambassador programme will help make a real difference.

For more information about the programme, and future training dates, visit https://coatingscareershub.com/ambassadors/ 

Frequently Asked Questions of the KKDIK Regulation (Turkey REACH)

With the pre-registration deadline for KKDIK quickly approaching on the 31st of December 2020, we at CIRS are busy monitoring the latest updates and preparing you to fulfil all the necessary obligations. Completion of the pre-registration obligation provides you with a grace period for registration until the end of 2023 after which all chemical substances manufactured/imported to Turkey in one ton/year must be fully registered.

To make this process easier for you, we have gathered all the most frequently asked questions from our practical experience to-date with the KKDIK regulation.

  1. If pre-registration is completed within C&L notification, then why should a foreign enterprise do the pre-registration themselves and not through a TR-importer?

If a TR-importer does C&L notification, they select the role of ‘importer’. The pre-registration will also have been completed under an importer. This may result in the following scenarios (a) higher cost for registration (b) the TR-importer may not do the registration and choose a supplier which has registered their substance with an OR (c) If the TR-importer does the registration, then they can buy the substance from any supplier they want as they will have the registration number. The result is an overall loss of commercial power in Turkey

  1. How is the pre-registration/registration of a polymer processed according to the KKDIK regulation?

Article 4 (hh) of KKDIK: Polymer means a substance consisting of molecules characterised by the sequence of one or more types of monomer units, distributed over a range of molecular weights wherein differences in the molecular weight are primarily attributable to differences in the number of monomer units and comprising of the following:

1) A simple weight majority of molecules containing at least three monomer units which are covalently bound to at least one other monomer unit or other reactant; and

2) Less than a simple weight majority of molecules of the same molecular weight

According to the KKDIK regulation, polymers are themselves exempt from registration. In the same way as EU REACH, it is the monomer unit and any other substances which are present in 1 ton/year or greater which require pre-registration/registration.

  1. For C&L notification of chemicals delivered in mixtures, does each individual substance require notification?

The way a mixture is classified is if the mixture contains a substance which is classified as hazardous and it is above the appropriate concentration limit (varies depending on the substance in question), then the mixture is classified as hazardous. If a mixture meets hazardous criteria, then C&L notification is required. Classification is the same as EU REACH.

  1. Is it possible to transfer completed pre-registrations?

Currently, the online platform for submitting pre-registration/registration dossiers is updating. This is the KKS tool (IUCLID and REACH-IT hybrid). This may take some time to complete. The OR transfer function will be available after the update is complete.

  1. According to KKDIK, all substances manufactured/imported into Turkey in 1 ton/year should be pre-registered. If my substance is less than 1 ton/year can it still be pre-registered?

Yes, it is still possible to pre-register substances which are less than 1 ton/year. This will also cover future business if annual tonnages rise to the 1 ton/year mark or above in the period of three years. If pre-registration is not completed before Dec. 31st 2020 and tonnages rise above the 1 ton/year threshold, then full registration will be required which will be far costlier.

  1. Is there a system of reporting dispatches into Turkey after pre-registration is completed?

Currently, there is not such a system in place for reporting dispatches

  1. When dealing with a mixture, if a raw material is pre-registered under the supplier, can the pre-registration be used by the formulator of the mixture?

This is the decision of the supplier who obtained the pre-registration number and whether he grants access to the formulator to use the pre-registration number.

  1. Who may register in the case of a multinational company/group companies?

This depends on whether each company within the same parent company are defined as ‘registrant’ according to Article 4(ü) of the KKDIK regulation. If multiple companies are under the same legal entity, then just one company needs to act as the registrant. In the case of a separate legal entity, such as a sister company, they should also register.

  1. How are alloys registered?

According to the KKDIK regulation, alloys are treated in the same way as mixtures. Therefore, each individual substance i.e. each metallic substance must be registered individually.

  1. If the tonnage band is expected to increase in the future, can the higher tonnage band be registered under instead?

Companies may register under higher tonnage bands if they expect their annual tonnage to increase. The higher registration fee must also be paid. Furthermore, the registration dossier must include all the required information for the higher tonnage band as data requirements differ between tonnage bands.

  1. If a company is importing a mixture to Turkey, how can they find out if the individual components have already been registered in Turkey by the supplier, if the supplier is refuses to share the information?

The options are to (a) Contact the formulator where the supplier is not the same entity as the formulator. The formulator may be more willing to share the composition information. (b) Take analytical measurements to determine the composition of the mixture or (c) Find an alternative supplier of the same substance who is willing to share the information

  1. Our substance only has a CAS No. and no EC No. is available, can we process pre-registration only with CAS No.?

Yes, there is no problem to process pre-registration without EC No.

  1. We are a distributor located outside Turkey, can we appoint an OR and process pre-registration?

No. It’s same as EU REACH. Only foreign manufacturers can appoint an OR and process pre-registration.

  1. Is there a definition of “new chemical” in the KKDIK regulation?

No. The regulation is only about the substance. There is no specific definition of Existing Chemical and New Chemical. CIRS suggests companies to process pre-registration of all their substances.

  1. If the manufacturer completes the pre-registration, can the local importer take C&L notification with this pre-registration No.?

No, if the importer processes C&L Notification, they have to firstly complete pre-registration by themselves.

  1. Our product contains a raw material which has not been reacted. The tonnage of this raw material is more than 1 ton/year. Are we still required to process pre-registration of this raw material?

It’s similar as EU REACH. If the raw material is not residual on purpose, it can be regarded as an impurity and pre-registration will not be required.

  1. We are a Turkish legal entity which owns several factories in different sites, how shall we process the pre-registration?

According to KKDIK regulation, registrant shall be the natural or legal person in Turkey. If the company has one individual legal entity which own different factories, and the factories have no individual legal entity, only one pre-registration is enough, and all factories will be covered.

If you have any further questions, please do not hesitate to contact us:

Julie Harrington, Regulatory Affairs Consultant

julie@cirs-reach.com

+353 0 87 197 2618

https://www.linkedin.com/in/julie-harrington-14270a160/

Metal Recycles Forever

80% of all metal ever produced is still in circulation today.

Recycling and sustainability

The UK metal packaging industry, along with its European counterparts, spearheads the continual drive to not only produce the most material efficient metal packaging possible, but also to provide packaging that offers other significant benefits such as significantly reducing food waste and producing paint cans that are still fully recyclable despite contamination from paint.

 

The industry’s recycling infrastructure, developed over many decades, has resulted in a UK recycling rate for steel packaging of 71 per cent and aluminium (primarily beverage cans) of 76 per cent.

 

The sector’s target of a 100 per cent recycling rate for metal is a real possibility thanks to metal’s easy separation from the waste stream, either by consumers at home or by magnetic extraction and eddy currents further down the line. And it’s a fact that all metal collected for recycling, is recycled and is reused.

 

Metal is officially recognised as a permanently available material (British Standard 8905) – a material whose inherent properties are not changed by repeatedly being recycling into new products. Metal can be recycled an infinite number of times with no loss of quality, and it’s estimated that 80 per cent of all metal ever produced is still in circulation today.

 

Metal’s sustainability credentials are captured in just three words: Metal Recycles Forever.

 

“Metal can be recycled again and again with no loss of quality, and when it is recycled it saves significant amounts of primary raw materials, energy and CO2. Once primary ore is converted into metal, as long as we look after it, we will have it forever.  This infinite recyclability is key to reducing the pressure on the world’s natural resources and why recycling metal is so important. Our vision is for a 100 percent metal packaging recycling rate,” said Robert Fell, Director and CEO, MPMA.

New Datacolor® Paint and Coatings Industry Guide

Many industries need to accurately measure, communicate and consistently reproduce colours. Effective colour management is important to business success for a number of reasons:

  • Colour consistency is associated with high quality
  • Colour can improve the safety and usability of products and environments
  • Colour problems can create unnecessary production expenses and delays
  • Colour management can help reduce environmental impact

 

In the new Datacolor® industry guide, the reader will find all they need to know about colour management and challenges in getting colour right. This free guide can be useful for anyone who works with colour. Get your guide now at https://bit.ly/34bpZwE

PCE-International’s latest marine-themed issue is now available online

In Lifting the Lid we hear from AkzoNobel. PPG, Teknos and Sherwin-Williams on their interpretation of sustainability and how they propose to deliver it

The Spotlight in this issue has a marine theme issue, with antifoulings in focus. Safinah puts biofouling under the microscope, and Hempel takes a look at antifouling evolution

In Focus continues the marine theme with Safinah looking at how to engineer the perfect paint finish. Hempel explains how vessel operators need to partner with suppliers to ensure the best possible fuel and emission savings across the entire docking interval, and we conclude by looking at advances in underwater coating inspection.

In Analysis, we investigate how pulse plasma nitriding systems can improve surface treatment and material performance, how specialised physical vapour deposition coatings can reduce friction between mated parts to improve performance, and feature an introduction to isosorbide

Update looks at wet pipe corrosion prevention, where the challenge faced by conventional protective coatings is the continuously wet surface of the pipe.  We also feature a polyurea solution used on the Cunduacán I Compression Station in Mexico

Review explores a solution for inhibiting corrosion in new bridge segments, and a sustainable solution to corrosion protection

The issue concludes with the latest products, appointments and industry News.

Check it out here:- PCE-International

And don’t forget to sign up for a FREE subscription!

What is sustainability?

AkzoNobel says sustainability is one of its core principles. “We strive to lead our industry by empowering people, reducing our impact on the planet and consistently innovating to deliver the most sustainable solutions for our customers,” explains Wijnand Bruinsma, Programme Manager Sustainability at AkzoNobel. “That’s why we call our approach to sustainable business “People. Planet. Paint.” It’s about focusing on the things we can truly influence.”

PPG’s sustainability approach is grounded in its vision of delivering lasting value for stakeholders and customers by operating with integrity, working safely, respecting the contributions of its people, preserving the environment and supporting the communities in which it operates.

Teknos believes that sustainability is the cornerstone. It wants to make the world last longer by providing smart, technically advanced paint and coating solutions and services to protect and prolong.

Sustainability has been embedded in the Sherwin-Williams way of doing business for over 150 years says Joao Azevedo, EMEAI Marketing Director for Sherwin-Williams Protective & Marine.

Read more about what these major paint companies think of sustainability and how they plan to deliver it in the latest issue of PCE-International