Published last February by the European Commission, the White Paper will have a major impact on the future of the paint industry, Dr. Matthias said. The aim of the White Paper is to improve the protection of health and the environment, establish a more transparent and workable regulatory framework for the chemical sector and stimulate innovation in the European industry—all of which CEPE supports. However, CEPE contends there are several weak points.
A fundamental shortcoming, according to CEPE, is that its proposals are geared to large companies in the chemical industry that often produce single chemicals in large quantities. This does not bode well for CEPE’s membership. “Our industry uses almost 10,000 different raw materials, many of them in small quantities, to make millions of different products,” Dr. Matthias said.
Another area of concern is intended use. The White Paper suggests that chemical manufacturers provide a risk assessment for the intended uses of a substance as part of its registration dossier. “While this concept sounds logical, it is based on the assumption that chemicals manufacturers know all the uses of their products,” Dr. Matthias said. Another reason is protection of intellectual property. Some downstream users that may not want to publicize the use of a certain additives in their formulations.
CEPE is also concerned about economic issues. “A chemicals manufacturer could decide to exclude certain uses from the list of 'intended uses' and thus save the money for the respective tests. In some cases, a raw material supplier may also decide to stop the production of a certain substance rather than going through the costly registration procedure. This is especially likely when the economic value of a substance stands in no relation to the cost of its assessment,” said Dr. Matthias.