Call for comments and evidence


4,4’-isopropylidenediphenol (Bisphenol A) and structurally related bisphenols of similar concern for the environment

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This call for evidence aims to investigate the manufacture, import, use and placing on the market of Bisphenol A and structurally related bisphenols of similar concern for the environment, as well as on the possibility for substitution, potential alternatives and on the socio-economic impacts of substitution. Information on the life cycle, emissions to the environment and the use in articles and occurrence in polymers is also of interest.

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 SECTION I. Personal information

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 SECTION II. Organisation

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 SECTION III. Non-confidential comments

Please provide your comments/answers in the comments boxes below (maximum 9 000 characters)

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 Specific Information Requests

Please provide your comments/answers in the comments boxes below (maximum 9 000 characters)

1: Sectors and processing of BPA and/or structurally related bisphenols: Please provide information on which sectors BPA and/or structurally related bisphenols are used including how it is transferred and processed, e.g. as a mixture of granules or article (materials/subassembly)?

2:

The specific use of Bisphenol A and/or structurally related bisphenols in (i) articles and (ii) mixtures (which are used, for example, to manufacture articles or mixtures):

For which articles/mixtures are BPA and/or structurally related bisphenols used. Is/Are they used as an additive or a monomer? Which technical function does BPA or structurally-related bisphenols have in the process or the material/article matrix (e.g. dye fixation agent, stabilizer, plasticizer)? Please provide the following additional information, where possible:

  1. The identity of the mixtures/articles containing BPA or structurally related bisphenols (intended e.g. as an additive and not intended e.g. as residual)
  2. Concentration of BPA or structurally related bisphenol in these products (differentiated into concentration total used, reacted, i.e. chemically bound, and unreacted BPA)
  3. Who are the users: are they consumers, professional or industrial users and how are the users processing the mixture/article?
  4. Quantity of BPA or structurally related bisphenols used in these products (e.g. as annual tonnage)
  5. Are measures in place to minimise releases during manufacture and handling of mixtures/articles and their life cycle? Do strictly controlled conditions exist or can they be implemented? If yes, please specify the measure(s) in place and if possible, the resulting release reduction[1].
  6. How long is the common service life for the mixture/article?
  7. What are the known stressors (e.g. UV-radiation, pH, temperature, moisture) for your article / mixture and how can they influence releases? What are your solution to prevent or minimise the releases?

[1] The wording of question 2(v) in version 1 of the background document was: Are measures in place to minimise releases during manufacture and handing of mixtures/articles and their lifecycle? If yes, please specify the measure(s) in place and if possible, the resulting release reduction.


3: Quality and testing of products (mixtures/articles): In the entry of the Registry for Intention, certain concentration limit values are proposed. Formerly, discussions were often about quality differences between imported products and products manufactured in the EU. Are the proposed concentration limit values technically feasible?

4:

What are potential alternative substances, alternative materials or technical alternatives to the use of BPA and structurally related bisphenols in mixtures and articles. Please provide the following additional information:

  1. Identity of existing or emerging alternatives and any information on the existing market share
  2. Technical and economic feasibility of potential alternatives, including information on product performance, the price differences between BPA, structurally related bisphenols and their alternatives, the number of products that could require reformulation, expected costs and timelines for reformulation and transitioning to a full-scale production using the alternatives, etc.
  3. Hazard and risk profile of the alternatives,
  4. Availability of alternatives in sufficient quantities on the market: current and future trends
  5. Other potential impacts stemming from the transition to alternatives, e.g. discontinuation of certain articles/mixtures, changes in product performance, article/mixture approval, etc.

5:

Socio-economic impacts on society:

  1. Costs and benefits to any affected actors, e.g. producers, professional or industrial users, consumers, or any other relevant actors (such as the producers of alternatives).
  2. Key economic parameters such as turnover of the concerned sector(s), the number of people employed, current share of products containing BPA or structurally related bisphenols, etc.
  3. Information on possible functional losses in case alternatives do not provide equal performance. Information should include quantitative or qualitative description of the overall impact of such functional losses.
  4. Information on imports and exports of substitutes and whether the actors will be impacted differently by a restriction.

6: Available analytical methods and test set up: For detecting the content pf BPA and structurally related bisphenols in and release from products, i.e. methods to determine the amount of residual or free BPA in different matrices as well as potential release of previously chemically bound BPA from articles/mixtures during the life cycle of articles/mixtures. Within the framework of stability tests prior to market launch or to certify the safety of articles/mixtures, there are specifications and standards for test setups. Which standards or test designs (e.g. for migration and leaching test) are you connected to?

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