Risk & Policy Analysts (RPA) Ltd, RPA Europe, RPA Prague, and Ökopol GmbH (Institut für Ökologie und Politik) have been commissioned by the German Federal Institute for Risk Assessment (BfR) to conduct an impact assessment on the introduction of a potential REACH restriction on skin sensitising substances when used in consumer mixtures. This includes all substances which have a harmonised classification of Skin Sens 1A or Skin Sens 1B or Skin Sens 1 under the CLP regulation (Regulation (EC) No 1272/2008) . While substances that are self-classified are currently not included in the proposed restriction, they may become relevant in the future, and so the project also seeks information on these.
REACH Registration data indicate the following consumer product categories potentially contain skin sensitisers and hence may be affected by the potential restriction:
| Product Category | Description |
| PC1 | Adhesives, sealants |
| PC15 | Products for the treatment of non-metal surfaces |
| PC18 | Ink and toner |
| PC23 | Products for leather treatment |
| PC24 | Lubricants, greases, release agents |
| PC3 | Air treatment products |
| PC31 | Polishing agents and wax mixtures |
| PC34 | Textile dyes and impregnating agents |
| PC35 | Detergents and cleaning agents |
| PC4 | Antifreeze and de-icing agent |
| PC9a | Coatings and paints, thinners, paint removers |
| PC9b | Fillers, putty, mortar, modelling |
The project will produce an impact assessment that includes:
- Identification of the skins sensitising substances that are used in consumer mixtures
- Understanding the functions provided by the skin sensitising substances in consumer mixtures (why they are used)
- The feasibility and suitability of potential alternatives to skin sensitising substances in consumer mixtures – can the skin sensitising substances be substituted?
- The potential health benefits, and socioeconomic impacts, if a Restriction on skin sensitising substances in consumer mixtures were to be enacted
RPA has prepared an online survey to engage with industry and to obtain data to support the above. This survey is an opportunity for industry to participate in the study, and to help shape a potential future Restriction Proposal by identifying the expected impacts and unintended consequences on industry and consumer products.
Instructions and guidance on how to use the survey (saving a draft, collaborating with colleagues) can be downloaded here.
A list of skin sensitising substances which have a classification of Skin Sens 1A or Skin Sens 1B or Skin Sens 1 under the CLP regulation, that have been identified as potentially being used in the given Product Category (PC) according to their REACH Registration, can be downloaded at this link.
We request and encourage interested parties to engage in the survey (which is hosted on the EU Survey platform) by clicking this link. All answers provided in the questionnaire (and any subsequent interview) are treated as confidential and will be visible only to RPA and the consultant team. All responses submitted in the survey will be handled confidentially. Only aggregated and anonymised data will be shared with BfR to protect individual companies’ confidentiality. If you have any enquiries about this project, please contact the project manager david.lever@rpaltd.co.uk
Dr Olaf Wirth is responsible for the project on the Ökopol side. You can also address questions to him at chemie@oekopol.de