Originally submitted by France and Sweden, the registry of restrictions intentions proposal includes restrictions on over 1000 substances in finished products, of which at least 90 are relevant for apparel and footwear. Also included is a novel provision dynamically linking harmonized classifications under the EU CLP Regulation to automatic restrictions. Substances that receive CLP classifications as category 1, 1A, or 1B sensitizer would be automatically restricted in finished products after a 36 month transitional period.
Stakeholders were given 60 days to provide feedback on the Draft Opinion of the Committee for Socio-Economic Analysis (SEAC). AFIRM’s Public Policy Committee submitted comments by the August 24th deadline, which included additional information on several general concerns previously raised along with responses to specific information requests. Recommendations for improving the proposal for the benefit of consumers, authorities, supply chains, and other important stakeholders are also included based on the collective chemicals management experience of AFIRM member brands going back over two decades.
As a next step, SEAC will review all comments received before adopting its final opinion. The European Commission then has three months to provide a draft amendment to the restriction list contained in Annex XVII to REACH. The final decision on whether to adopt the proposal will be taken in a comitology procedure with scrutiny involving the Member States and the European Parliament. If adopted, the restriction will go into effect after 36 months.
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