JBCE's Environment & Energy Committee submitted its views following the call for comments on the draft scientific dossier (Annex D) for an EU proposal for the listing of D4, D5 and D6 in Annex B to the Convention

10/08/2023

On 10^th August 2023, JBCE submitted its views on the draft scientific dossier (Annex D) for an EU proposal for the listing of D4, D5 and D6 in Annex B to the Convention.

 

JBCE understands that the proposed draft scientific dossier is in line with the target of having “a zero-pollution ambition for a toxic-free environment”. However, silicone polymers made from raw materials including D4, D5, and/or D6 with special properties are not only used for the various final products across a wide range of sectors as essential key materials, but they also contribute to achieving the goals of the European Green Deal. In addition, finding alternative substances with the same special properties as silicone polymers poses significant challenges.

JBCE strongly recommends ECHA to consider: (1) the risk assessment for the environmental release of D4, D5 and D6 from the applications using silicon polymers, (2) the analysis for the socio-economic impact of subjecting silicone polymers to restrictions, and (3) the specific derogations for the applications using silicone polymers similar to the ones in the Stockholm Convention decision for UV-328.

 

You can download our position below.

For more information please contact:

Masakazu Shimosawa, Policy Manager, Environment & Energy (This email address is being protected from spambots. You need JavaScript enabled to view it.)