ECCA's complete comments are provided in the attached document. ECCA's comments are summarised as follows: 1. the legal basis for the proposed Regulation is questionable, since it combines amendments that require a different Comitology process 2. the manner of selecting substances for listing in Annex III is questioned.
EU consultation
Co-formulants in pesticides
19 submissions from 19 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 23 submissions on this file. Shown here: the 19 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
16 submissions from industry — companies and their trade associations — against 2 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 8 industry submissions for every one from civil society.
Industry 16Civil society 2Public authorities, academia, other 1
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 13 Feb 2020 — it ran from 16 Jan 2020.
- Policy area
- Health & food (DG SANTE)
- Where it stands
- Awaiting adoption
How it got here
- Reg draft13 Feb 2020
Also on the Commission’s pipeline for this file, with no date recorded: Reg.
Showing 19 of 19 submissions.
The Health and Environment Alliance (HEAL) welcomes the opportunity to comment on the European Commission proposed amendment of the annex III of regulation 1107/2009 (thereafter PPPR) listing co-formulants which are not accepted for inclusion in plant protection products (PPP).
CI
Confcommercio - Imprese per l'Italia
· · filed 13 Feb 2020 · source
With regard to this initiative, we would point out that the proposal for the disposal of plant protection products provides for a compliance period of only three months. We believe that this period is particularly low especially in view of the fact that plant protection products are seasonal and often limited to certain phenological stages of a crop.
Filed in Italian · English published by the European Commission
We, Imerys SA, hereby ask for the removal of the naturally occurring mineral “Aluminium silicate (kaolin)” from the draft list of unacceptable co-formulants in Annex III of Regulation (EC) 1107/2009 and for the revision of the limit on quartz sand as an unintentional impurity.
SS
Sepiol. S.A.
· · filed 13 Feb 2020 · source
We hereby ask the removal the entry “attapulgite” (palygorskite) from the draft list of unacceptable co-formulants in Annex III of the Regulation (EC) 1107/2009, considering the following facts: - The substance “attapulgite” (palygorskite) has not been classified as Carcinogen 1A in Annex VI of the Regulation (EC) 1272/2008 (CLP) - There are not notifications of this substance as carcinogen 1 in the ECHA C&L…
The SEMI-F, Minière Industriels-France represents the companies involved in the extraction and processing of industrial rocks and minerals. Andalusite, clays, calcium carbonates, feldspar, kaolin, mica, quartz, silica, silica, talc, etc. situated ahead of the French industrial value chain, the sector of the Médiales Industriels sector is the first indispensable link in the supply of avant-garde industries.
Filed in French · English published by the European Commission
Subject: EC public consultation on the revision of Annex III to Regulation (EC) No 1107/2009 of the European Parliament and of the Council concerning the placing on the market of plant protection products We are writing to you regarding the 5 natural minerals included in this list: 1. Aluminium silicate (Kaolin) 2. Cristobalite (crystalline silica polymorph) 3. Quartz sand (crystalline silica polymorph) 4.
Filed in French · English published by the European Commission
?
Ελληνικός Σύνδεσμος Φυτοπροστασίας
· · filed 13 Feb 2020 · source
We believe that there are two critical points in the proposal which will have a negative impact on the successful evaluation of co-formulants used in plant protection products (in accordance with Regulation 1107/2009, Annex III).
Filed in Greek · English published by the European Commission
The International Diatomite Producers Association (IDPA) is a trade association representing major manufacturers of diatomaceous earth products worldwide. Founded in 1987, IDPA is committed to the safe use of diatomaceous earth products and to advancing research and maintaining a dialogue with industry, legislators, regulatory agencies and the scientific community in support of the safety of our employees, our…
AK
Amberger Kaolinwerke Eduard Kick GmbH & Co. KG
· · filed 13 Feb 2020 · source
We refer to the 5 naturally occurring minerals containing silicon dioxide that are now included in this list. These minerals are: Ö 1. Aluminium silicate (kaolin) Ö 2. Cristobalite (multimorph of crystalline silica) Ö 3. Quartz sand (multimorph of crystalline silica) Ö 4. Silicon dioxide (Keselgur) Ö 5. Trydimitite (multimorph of crystalline silica).
Filed in German · English published by the European Commission
HS
Hydrocarbon Solvents Producers Association - HSPA
· · filed 12 Feb 2020 · source
The Hydrocarbon Solvents Producers Association would like to make the following comment: The cut-off concentrations for those substances listed in Annex III should be based on the REACH / CLP regulatory cut-off concentrations of 0.1 % w/w in the final mixture.
EUROSIL was founded in May 1991 as the official body representing the European industrial silica producers. The association provides its members with a forum in which to tackle regulatory, technical, health and safety and environmental issues and assures the representation of industrial silica at national and EU authority levels.
KPC-Europe provides sector-based representation for naturally occurring minerals kaolin and clays. KPC Europe is involved in all non-commercial issues related to the properties and safe use of minerals, from their extraction and processing through to their end-use applications.
We hereby ask the removal of the following naturally occurring minerals from the draft list of unacceptable co-formulants in Annex III of Regulation (EC) 1107/2009: 1. Aluminium silicate (Kaolin) 2. Cristobalite (crystalline silica polymorph) 3. Quartz sand (crystalline silica polymorph) 4. Silicium dioxide (kieselguhr) 5. Trydimite (crystalline silica polymorph) 6.
EUBA provides sector-based representation for naturally occurring sorptive minerals such as bentonite, attapulgite or sepiolite. EUBA is involved in all non-commercial issues related to the properties and safe use of minerals, from their extraction and processing through to their end-use applications.
TS
TOLSA S.A.
· · filed 11 Feb 2020 · source
The proposal of Annex III of Regulation (EC) 1107/2009 states, under the initial explanatory section, under point 4, that the list of unacceptable co-formulants should include substances with a harmonised classification as carcinogens, category 1A or 1B, as cell mutagens, category 1A and 1B, or as toxic to reproduction, category 1A or 1B, in accordance with Annex VI to Regulation (EC) No. 1272/2008.
BU
The prohibition of: Kaolin Diatomaceous earth Quartz sand Trydimite (SiO2) as co-formulants, there is an urgent need to review them. Where is the scientific evidence for this requirement in the “Annex” table? From the point of view of formulation chemistry, it makes no sense to place the ingredient as such on the annex. The amount of particles < 50 µm and their bioavailability and exposure (e.g.
Filed in German · English published by the European Commission
Please see additional file attached with detailed comments. • ECPA emphasizes the critical importance that the relevant cut-off concentrations for those substances listed in Annex III also be based on the REACH / CLP regulatory cut-off concentrations of 0.1 % w/w in the final mixture.
FC
Fachverband Chemische Industrie Österreichs
· · filed 4 Feb 2020 · source
General principles: The substances used as co-formulants are general chemicals and are already subject to the provisions of the REACH and CLP Regulations. The provisions of the REACH and CLP Regulations should therefore be used as a basis for the preparation and future additions/amendments to Annex III to Regulation (EU) No 1107/2009.
Filed in German · English published by the European Commission
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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.