Restricting the placing on the market of mixtures and articles where concentration is equal to or greater than 10 ppm (0.001 % by weight).
The first condition shall not apply to mixtures and articles where the bisphenols in the scope of the restriction are either covalently bound to any type of matrix (e.g. via functioning as a cross-linker) or are used as intermediates in the manufacture of polymers, and for which
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It is possible to provide both general comments on the Annex XV restriction report subject to this Consultation and answers to the specific questions posed. In both cases, it is necessary to provide supporting evidence to allow ECHA’s Committees to take your comments into account. It is important not to leave the submission of any socio-economic information until the consultation on SEACs opinion but already submit relevant comments at this stage.
General Comments
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Please provide your general comments in the box below
Restriction conditions and testing
Do you consider that the restriction conditions (including derogations listed in Appendix Y) and the conditions and methods for migration testing (as described in Annex Z) are clear? Are there conditions that require further clarification? Do you consider that the conditions and methods for migration testing as described in Annex Z are representative to assess migration during the entire article service life? If not, can you propose a more reliable testing?
* Compulsory Fields
Which analytical methods exist for your sector to test:
In your answer, please specify the aim and purpose of the testing (for example, testing in the context of testing REACH conformity, characterising performance or stability).
Which solvent do you use to extract BPA and/or BosC in either content or migration testing?
Alternatives
The Dossier Submitter identified different alternatives for the different uses of Bisphenol A and BoSC (e.g. in PVC, thermal paper, hardeners for epoxy resins, polycarbonates, epoxy resins, polysulfones, polyesters, phenolic resins, polyurethanes, vinyl ester resins, polyacrylates, syntans, fluoroelastomers). These are described in section E.2 of the Appendix. Do you agree with the Dossier Submitter’s conclusion regarding the availability of alternatives? Do you have additional information on alternatives that should be considered as part of the Impact Assessment.
Product specific questions
Epoxy resins
For manufacturers or importers of epoxy resins: do you have information on the presence of BPF or BoSC in your products? If BPF or BoSC are present in your products, please can you indicate the concentration, the methods used for the testing and the volumes of epoxy resins produced per year in the EU. Do you have information on the expected growth in demand for epoxy resins in the EU in the next 5 years and more (e.g. up to 20 years)?
Synthetic tanning agents (Syntans)
You are invited to provide information on:
Synthetic tanning agents used for polyamide treatment (textile auxiliaries)
Emissions
During the manufacture of your products or their use, which measures do you employ to minimise the amount of “free” BPA/BosC in them?
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