France Intensifies Battle Against Hormone-Disrupting Chemicals

The French Ministry for the Ecological and Solidary Transition (Ministère de la Transition écologique et solidaire) and the Ministry for Solidarity and Health (Ministère des Solidarités et de la Santé) have published a strategy paper (French only) against endocrine-disrupting chemicals (EDC).

The authors define three areas of action: 

  1. To provide the public with more-comprehensive information on the topic than it has ever receivedpreviously: One of the measures that France plans is to create a list of EDCs that it will share with the EU Commission and other member states. Because pregnant women and children are particularly at risk, the French health agency, Santé Publique France, created a new Web site, Agir pour bébé. Parents can visit the site to find suggestions for how to minimize exposure to chemicals.  
  1. To protect the public and the environmentbetter: France has appealed to the EU to supplement the regulations on cosmetics and toys in terms of EDCs. Its data portal also provides more information on exposure to EDCs.
  1. To enhance research into the health effects ofEDCs: The French health agency published a study on the spread of EDCs at the beginning of September. Some 1,100 children and 2,500 adults took part in the study. The researchers found endocrine-disrupting substances, including bisphenol derivates A, F, and S; phthalates; parabens; and glycol ethers, in all study participants.  

The EU summarized its strategy at the beginning of November 2018.

If you have any questions about EDCs, please contact us at

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New Zealand Suggests Modifications to Its Chemicals Law and Opened a Consultation

The New Zealand (Ministry for the Environment (MfEis seeking to improve its Hazardous Substances and New Organisms Act (HSNO) and has already published some suggestions. From August 19 to September 30, stakeholders can make their positions known as part of a public consultation.

The goal of the initiative is to replace hazardous chemicals with harmless alternatives more quickly. Although better substances often exist, they remain unused because the assessment required by import/export laws is too expensive for companies and the overall process takes too long. That’s the opinion of the David Parker, New Zealand’s minister for the environment, in the forward to a discussion paper, Hazardous Substances Assessment: Improving Decision-Making.

According to the document, the responsible agency, the Environmental Protection Authority (EPA), has reassessed 51 substances since 2001. Some 39 more that urgently require reassessment are now waiting in the queue.

The ministry urges that chemicals data already assessed elsewhere, such as in the EU, the United States, Australia, or Canada be accepted in New Zealand. It sees no need to reinvent the wheel.

We are thoroughly familiar with the regulations in New Zealand.
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Turkey Aligns Its Regulations with the EU Cosmetics Regulation

The Turkish health ministry has aligned its legal regulations on cosmetics with the requirements of the EU Cosmetics Regulation (only in Turkish).

The following concrete changes result:

  • Turkey prohibits 2-chloro-p-phenylenediamine along with its sulphate and dihydrochloride salts in hair, eyebrow, and eyelash-dye products.
  • Turkey limits the use of 1-(4-chlorophenoxy)-1-(1H-imidazol-1-yl)-3,3-dimethyl-2-butanone (Climbazole) in dandruff shampoos and as a preservative in hair lotions, face creams, and footcare products. Other uses in cosmetics are prohibited.
  • Turkey allows the use of Climbazole in hair lotions, face creams, and footcare products in concentrations up to 0.2%. Other uses are prohibited.
  • Turkey allows the use of preservative o-phenylphenol in leave-on products up to a maximum concentration of 0.15% and in rinse-off products up to a maximum concentration of 0.2%.
  • Turkey permits the use of UV filter phenylene bis-diphenyltriazine in sunscreens in concentrations up to 5%. It prohibits use of the chemical in products that can lead to inhalation exposure.

In the EU, Regulation 2019/681 of the EU Commission applies to 2-chloro-p-phenylenediamine. According to Annex II of Regulation (EC) No. 1223/2009 (the Cosmetics Regulation), hair dyes and products to dye eyebrows and eyelashes that contain 2-chloro-p-phenylenediamine along with its sulphate and dihydrochloride salts may not be marketed in the EU after November 22, 2019. After February 22, 2020, they may not be sold in the Union market.

In the EU, Regulation 2019/678 applies to Climbazole. According to Annex II of the Cosmetics Regulation, Climbazole may be used in rinse-off products only in a concentration of 2%. As of November 27, 2019, cosmetics that contain Climbazole in excess of these limits may no longer be marketed. They may not be sold in the Union market after November 27, 2020. And Annex V of the Cosmetics Regulation permits the use of Climbazole in hair lotions, face creams, and footcare products only as a preservative in a concentration up to 0.2%. Other uses are forbidden.

EU Regulation 2018/1847 applies to o-phenylphenol. The chemical may be used in leave-on products up to a maximum concentration of 0.15% and in rinse-off products only in a concentration up to 0.2%.

EU Regulation 2019/680 applies to phenylene bis-diphenyltriazine. According to Annex VI of the Cosmetics Regulation, use of phenylene bis-diphenyltriazine as a UV filter in sunscreens in a concentration up to 5% is safe and permitted. However, it is not allowed in sprayable products.

We have supported companies operating on the Turkish market for many years. If you
have any questions, please contact us at

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Toxic Hygiene Products: Petition Puts Pressure on EU Supermarket Chains

A social media campaign, #MyClosestEnemy, warns about purchasing personal care products like tampons and baby diapers that have been bleached with chlorine dioxide. Rune Leithe, former Greenpeace campaigner and initiator of the campaign, has already collected 20,000 signatures on a petition. He is appealing to large EU retail chains to stop the sale of the problematic products and to shift production to chlorine-free alternatives.

The background of the criticism is a report, Tampon, Our Closest Enemy, by French journalist Audrey Gloaguen. In the document, he emphasizes that tampons bleached with chlorine dioxide can contain toxic dioxins. That’s why the WHO has classified these products as hazardous.

Leithe published the related figures on his Web site. He indicates that most women will use about 11,000 tampons and pads during their lifetimes, which leads to a high exposure to carcinogenic dioxins. According to Leithe, manufacturers are not legally required to indicate the presence of these hazardous and other chemicals on their product packaging.

Most types of diapers are also criticized. French agencies have reacted to a report from the French Agency for Food, Environment and Occupational Health and Safety (ANSES) and have urged manufacturers to examine their production processes and monitor their raw materials more closely. We reported on this report in an earlier article.

We can help you ensure the legal compliance of your products. Please contact us at

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Nanomaterials: Guidance for Safe Disposal

The German Chemical Industry Association (VCI) has published Guidance to support companies in the safe disposal of waste that contains nanomaterials.

Nanomaterial waste cannot be avoided in the production and use of nanomaterials. With the document, the VCI assists companies that use nanomaterials as UV filters in sun blocks, soil repellents in fabrics, and flame retardants in furniture.

The Guidance highlights the following issues: 

  • Legal framework 
  • Conclusions of legal requirements 
  • Safe recovery or elimination of waste that contains nanomaterials 

Chapter 4.3 of the Guidance (German only) is noteworthy in this context because it concerns communication in the supply chain. The authors indicate that a safety data sheet (SDS) must be created for hazardous chemicals and mixtures (and for PBT/vPvB substances and chemicals) on the candidate list for REACH registration procedures. Information on disposal can be found in section 13 of the SDS. For additional information, see the ECHA Guidance on the Creation of Safety Data Sheets. 

Do you deal with nanomaterials and have any questions? Please contact us at 

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Philippines: New Department to Act Against Illegal Chemical Imports

The Philippine Bureau of Customs (BOC) wants to limit the import of hazardous chemicals and to that end has issued Customs Memorandum Order (CMO) No. 38-2019 that took effect on August 9. The CMO envisages a new department, the Environmental Protection and Compliance Division (EPCD). In the future, its staff is to monitor the transport of chemicals and, as a first step, develop guidelines. With the new department, officials want to prevent the illegal import of hazardous chemicals and monitor the import of hazardous waste (including nuclear waste) and other chemicals more closely.

The procedure should be as follows: EPCD employees perform investigations. If they suspect that a shipment contains goods that do not comply with the environmental laws and the requirements of the Customs Modernization and Tariff Act (CMTA), the BOC becomes involved and inspects the shipment more closely. If the second inspection confirms the suspicion, the BOC will issue a warrant and confiscate the goods.

The Toxic Substances and Hazardous and Nuclear Waste Control Act (RA6969) has been in effect in the Philippines since 1990. The law regulates the import, manufacture, processing, handling, storage, transport, sales, marketing, use, and disposal of all non-regulated chemical substances and mixtures.

When manufacturers or importers want to bring into the country a substance that is not listed on the Philippine Inventory of Chemicals and Chemical Substances (PICCS), they must register the substances with the Department of Environment and Natural Resources (DENR).

In this context, we would like to refer to the lecture given by our colleague Dr. Tobias Eger at the seminar „International Chemicals Law on September 26–27, 2019“ in Frankfurt. KFT’s expert on East Asia will discuss the newest developments in chemicals law in Malaysia, Vietnam, and Philippines.

If you have any questions on this topic, please feel free to contact us at 

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RoHS Directive: What’s New?

In the European Union, the amended RoHS Directive (Directive 2011/65/EU of June 8, 2011 on limiting the use of specific hazardous chemicals in electric and electronic devices has been in effect since July 22, 2019. The Directive lists various chemicals that may not be used in electric and electronic devices. Since the effective date, two important revisions have been made for users.

First, as of July 22, 2019, four additional prohibitions on the hazardous chemicals in electric devices have been added to the earlier prohibitions. As published in the amending directive (Directive (EU) 2015/863 of March 31, 2015, the following four phthalates will be forbidden, along with lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE):

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

Second, as of July 22, 2019, Article 2, Section 2 of the RoHS Directive also applies to the devices listed in Annex I under Category 11 that have so far been exempt. These devices include other electric and electronic devices that cannot be assigned to any of the categories already noted.

Annex III of the RoHS Directive lists uses exempt from restrictions. The exemptions have now been expanded because in August, the EU issued a five-year RoHS exemption for the use of DEHP in the rubber components of engine systems. It also approved a five-year exemption for the use of lead in solder of sensors, actuators, and engine control units of combustion engines.

In Germany, the revisions have been realized in the national electronic chemicals ordinance (German only).

If you have any questions about the RoHS Directive, please contact us at

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