Issue 102 November 2023INFORMED COMMENT FROM THE BRITISH ADHESIVES & SEALANTS ASSOCIATIONBulletinRead xtonnes' arcle about carbon accounng and how it can help your business stay ahead of the curve.10The deadline is fast approaching, read the arcle from BASA's Regulatory Ocer Caroline Raine on how we can help you make these nocaons.Read about the EU Dra Toy Safety Regulaon and alll the proposed changes made in July 2023 by the European Commission.It has been a busy year for BASA, with a full programme of events being run for the rst me since 2019. We have been able to run a Business Forum before the March AGM held at the cinch Stadium, Northampton and an Open Industry Forum at Sketchley Grange Hotel, Hinckley in November. Before both in-person events we were able to produce hard copy bullens for all the delegates to catch up on the work that has been going on. Sports day was well aended by the shoong cohort, and although the number of golfers were a lile down on previous year, they sll had a great day. All golfers should pencil in the date of next year’s Sports Day – June 19th, 2024 – to hopefully avoid a clash with other golf days!It is a signicant challenge for all of us to stay on top of the dual regulatory schemes we now nd ourselves exposed to, and we are starng to see more fallout from Brexit in terms of goods being held up by addional customs checks by EU member states. These checks are not being carried out because the UK le the EU, but rather because the EU commission cricised some of the member state customs controls in respect of a lack of EU REACH compliance checks for products being imported into the EU. Sadly, the UK is probably more vulnerable than other countries to this as fewer UK manufacturers have appointed an EU A note from legal enty to take care of EU REACH obligaons. This potenally leaves BASA members exporng to the EU more exposed. We are going to be running some more clinics on how to make sure you have the proper paperwork and declaraons to try to help members navigate this complex situaon. In August this year the Brish government announced that it would delay imposing full post-Brexit import controls on goods from the European Union by a further three months, pushing the start date back to January 2024. Potenally this means that from that date any imports of adhesives and sealants from the EU will need to be able to prove UK REACH and GB CLP compliance. To benet from the Trade and Cooperaon Agreement (TCA) zero tari, businesses must show the origin of their goods. A product qualies as ‘originang’, if it is ‘wholly obtained’ in the UK and EU or has been substanally transformed in one or both markets. As rules of origin are product-specic and compliance can be onerous, it is hoped that the import controls do not cause unexpected issues next year. Please connue to let us know of any specic problems so that we can look to help.We connue to work with the other UK Chemical Associaons to push for government to rethink the current UKREACH regulaon, and the whole issue of UKCA marking of Construcon Products connues to be hugely challenging. We are trying to develop some addional guidance documents in relaon to UKCA marking against a European Assessment Document (EAD) and connue to engage with DLUHC to understand what their real intenons are in respect of future UK Construcon Products Regulaons. Will the current Government actually try to pass new legislaon to enforce the intended date to cease recognion of CE marking (30/6/2025) before the general elecon next year – or will they leave to the next government?Finally – I hope to see some of you at BASA’s annual dinner, being held at the Chester Grosvenor Hotel on Saturday 2nd December. We understand that condions for business are not easy at present but try to support the Associaon and buy a couple of ckets to join us at this year’s dinner and take advantage of the networking opportunity. It should be a great evening.41st AGM & Industry Lunch, Thursday 7th March 2024, Manufacturing Technology Centre (MTC), Coventry8
BASA Bullen Issue 102 BASA Bullen Issue 1022For this years BASA Annual Dinner we will be returning to the CHESTER GROSVENOR Hotel on Saturday 2nd December 2023. The event was last held here in November 2019, we are looking forward to seeing BASA Members embrace the Christmas spirit and join us for a night of good food and good company. Sponsorship Package includes; • Social media promoon • Publicity in the BASA Bullen • A one page advert in the 2024 BASA Members Handbook • Table for 8 aendeesThere are only 3 Gold Sponsorships available for this event.You are all working really hard so this is a chance to let your hair down and have some well deserved entertainment and a night of social networking and fesvity.The ISO meeng this year took place on 27th and 28th September in Paris and was aended by representaves from 8 countries. The Secretariat is held by China and Chaired by Mr Ruud De Block from the Netherlands. The work on high movement was closed o with a decision to make no changes to introduce new classes to ISO 11600. The commiee also resolved to start a new work item to develop a classicaon standard for Sanitary Sealants, incorporang ISO 21265:2021 Building and civil engineering sealants — Assessment of the fungal growth on sealant surfaces. It was agreed that a similar process to the development of ISO 11618 “Classicaon and requirements for pedestrian walkway sealants” would be adopted and Lorna Williams was appointed as convenor for the project. Other work in the next 12 months will be to connue to work on Aesthec Issues through WG10, where a dra will be published, some further work on Paint Compability, and also WG1 “UV Inuence” will be reacvated to revise ISO 11431 in the next 24 months. We have an urgent request for addional UK parcipants for ISO TC 59 SC8, parcularly to stand as an expert for WG25 Sanitary Sealants. The next meeng is in October 2024 in Japan.
3 BASA Bullen Issue 102 BASA Bullen Issue 102This issue of the BASA Bullen is published to coincide with our rst Open Industry Forum for our technical community held face to face since the pandemic. It is hard to realise that it has been more than three years since we last met in this way. In the meanme, technology has come to the rescue of our technical work, even increasing eecveness and cost eciency, and broadening our reach and accessibility for the technical sta of our members. All our regular working group and commiee meengs are now held virtually, saving sta me and cost. The popular weekly drop-in clinics, the programme for which is published on the BASA website, are open to all BASA members where current topics are researched and presented, and new issues raised. If you are free one Friday morning at 10 am I advise you to join and see for yourself. However, having said all that, we believe that there is no substute for in person meengs to build relaonships, so this format will connue at least once each year.The technical work we undertake remains at the heart of the associaon providing valuable insight on an increasingly broadening list of issues to the membership and providing a route to input to the development of regulatory and standardisaon issues both in UK/GB and EU via FEICA.Jim Palmer, Technical Ocer, J P ConsultancyAs predicted our workload has been dramacally increased by the exit from the EU as we now have twice the number of legislave processes to follow. However, our redened reciprocal relaonship with FEICA has eased the burden somewhat, combined with an increase in the technical resources allocated by Council.The BASA web site is an invaluable source of informaon for members and is being connuously developed to improve accessibility. An issues map, which links all the up-to-date informaon on the many key issues, supplements and collates the regular working group posngs, which are also noed on a weekly basis to subscribing members.If you aended the Open Industry Forum on 2nd November, you will have read the latest situaon on the hoest issues on the working poster displays, which are summaries of the web pages on the web site. If you weren’t able to aend, then you missed a great day! I will comment on just a couple of key topics: In Europe following a prolonged consultaon the EC has chosen to enhance the CPR to meet their objecve of a single market for construcon products. Whereas in the UK/GB, where barriers to cross border trade are irrelevant, decisions are to be made by Industry/government about whether to reserve the use of the UKCA mark for safety crical products only as indicated by the building safety bill. Consequently, rumours abound that recognion of CE marking in UK may connue indenitely, especially in view of the lack of approved bodies to carry out the necessary test work. Cessaon of the recognion of CE marking in GB connues to a stated government aim but this cannot happen unl actual legislaon is brought forward. Mutual recognion is the only real answer to avoiding excessive repeat tesng. Mutual recognion agreements already exist between EU and other world bodies so why not between EU and UK?In UK the plasc packaging tax has driven the change to packaging that contains minimum 30% recycled material to avoid the tax. However, the new Collecon of Packaging Reform (CPR) reporng requirements are very complicated, and the implementaon has had to be delayed pending further consultaon. The intenon is for brand owners to fund the collecon and recycling cost of local government for household waste and the current classicaon system defaults packaging to ‘household waste’ unless other routes can be proven.Addionally, the divergent approaches around Europe to meet the aims of Extended Producer Responsibility regulaon is a potenal problem for members supplying into Europe. As always, I would like to thank my technical colleagues for their commitment and hard work, and I would encourage you all to consider volunteering on the working groups. It is an excellent way to keep up with the latest developments in regulaons and standardisaon. The me commitment is a maer of personal choice but can be minimal and those who parcipate fully nd it a great contribuon to their own personal development. Please do explore the members area of the BASA website to see what appeals.BASA Sports Day, Wednesday 19th June 2024, Hawkstone Park Hotel & West Midlands Shoong Ground, Shropshire
BASA Bullen Issue 102 BASA Bullen Issue 1024The Industrial use deadline is looming (1stJanuary 2024). Importers and downstreamusers of industrial use only mixturesneed to comply with the harmonisedinformaon requirements outlined inAnnex VIII to (EC) No 1272/2008 onclassicaon, labelling and packaging(CLP) of substances and mixtures andsubmit a poison centre nocaon via theECHA harmonised portal to the MemberStates where they are placing on themarket.(Note - If an industrial use only mixtureis on the market and already noed vianaonal submission systems before the2024 compliance date, it may benetfrom the transional period unl 1January 2025. This means that aer thisdate, all nocaons, regardless of theuse type, will need to be noed in theharmonised format.)Northern Ireland follows the Annex VIIIrequirements, but not through the ECHAportal. Instead, once the Annex VIIIdossier has been created it should be sentto the NPIS.Because NPIS does not have accessto the European Chemicals Agency(ECHA) poison centre nocaon (PCN),submissions for NI must be provided inthe form of a PCN and sent directly toNPIS Birmingham as the appointed body.In order for submissions to be valid, theymust be either:• produced directly in the ECHA-approved IUCLID desktop/cloudplaorm and exported as an .i6zdossier• if produced using a third-party tool, the submission must then beimported into the ECHA PCN, andexported as an .i6z dossier. Thisexported dossier will be accepted byNPIS as a submissionThese submissions should be made viaemail to sds.npis@nhs.netYou must also include a UFI in thesubmission of informaon and on thelabel or, in some cases, the packaging ofthe products that contain a hazardousmixture.More informaon on Northern Irelandand Poison centres can be found on theGOV UK website here:www.gov.uk/guidance/subming-chemicals-informaon-to-the-naonal-poisons-informaon-service www.eventcreate.com/e/pcworkshop
5BASA Bullen Issue 102 BASA Bullen Issue 102The EU taxonomy is a cornerstone of theEU’s sustainable nance framework andan important market transparency tool. Ithelps direct investments to the economicacvies most needed for the transion,in line with the European Green Dealobjecves.The taxonomy is a classicaon systemthat denes criteria for economic acviesthat are aligned with a net zero trajectoryby 2050 and the broader environmentalgoals other than climate.So eecvely it is a classicaonframework that determines whetheran economic acvity is environmentallysustainable and under EU legislaon,“large” EU companies will soon need toreport on their taxonomy “alignment”as part of their mandatory sustainabilitydisclosures.So very simply, this means reporngon the extent to which the acvity oftheir business corresponds to whatthe EU views as “environmentallysustainable”. Unfortunately this will catcha lot of large subsidiaries of US and otherinternaonal businesses and it is likelyto be a complicated exercise for manybusinesses, and one that they have nothad to undergo before.The Taxonomy Regulaon entered intoforce on 12 July 2020. It establishes thebasis for the EU taxonomy by sengout the 4 overarching condions that aneconomic acvity must meet to qualify asenvironmentally sustainable.Under the Taxonomy Regulaon, theCommission had to come up with theactual list of environmentally sustainableacvies by dening technical screeningcriteria for each environmental objecvethrough delegated and implemenng acts.The Commission created an educaonaland user-friendly website oering aseries of online tools to help usersbeer understand the EU taxonomy in asimple and praccal manner, ulmatelyfacilitang its implementaon andsupporng companies in their reporngobligaons. : a visual representaon of sectors, acviesand criteria included in the EUTaxonomy delegated acts : a step-by-step guide on reporng obligaons : an overview of quesons and answers on the EUtaxonomy and its delegated acts : a guidance document on the Taxonomy for non-expertsFind out more about the EU taxonomynavigator by heading to the website:hps://ec.europa.eu/sustainable-nance-taxonomy/Synthomer plc are pleased toannounce they have receivedInternaonal Sustainability andCarbon Cercaon system (ISCC)PLUS cercaon. ISCC PLUScercaon is an internaonallyrecognised sustainabilitycercaon which veries thetraceability of incoming andoutgoing sustainable materialalong the value chain.Synthomer plc has been ceredas a trader with storage whichmeans Synthomer is able to buy,store and trade ISCC ceredproducts.This is an important milestone forSynthomer as it enables divisionsto pursue site specic cercaonwhich will put us in a good posionto oer ISCC cered sustainableproducts to customers using themass balance approach. ISCCcered raw materials such asButyl Acrylate, Gum Rosin, C5,Styrene, Butadiene, Acrylonitrileare in scope for site speciccercaon.The cercate is available on theirwebsite here:www.synthomer.com/about-us/cercaons/
BASA Bullen Issue 102 BASA Bullen Issue 1026The FEICA 2023 European Adhesive& Sealant Conference and EXPO tookplace at the PortAventura ConvenonCentre in Tarragona, Spain, from 13 to15 September 2023 and was aended byalmost 700 delegates.This year’s event focussed on how toachieve your sustainability goals. Photosof the event are available via the FEICAConference Media Gallery here:www.feica-conferences.com/the-conference/media-gallery/2023-photo-gallery/. Market changes throughCircular Economy by Flor PeñaHerron, Chair of the FEICASustainable DevelopmentCommiee, Avery Dennison• Prepare your porolio for upcoming substancerestricons by KimSuetens, Chair ofthe FEICA MixtureAssessment TTF and ViceChair of the Polymers TTF, Soudal• Status report on FEICA advocacy by Peter Boris Schmi, Chair of the FEICAEuropean Advocacy Group, Henkel• Challenges and opportunies for packaging adhesives by ElizabethStaab, Chair of the FEICA Sustainability& Recycling of Adhesives in Paper &Packaging Applicaons TTF, H.B. FullerThe 2024 FEICA Conference & EXPOwill be held at Noordwijkerhout in theNetherlands, from 11 to 13 September2024. Registraon will open at thebeginning of 2024, so SAVE THE DATE!You can read more on this year'sconference in the forthcoming edion ofFEICA CONNECT, out in November.The market study programme, tled ‘TheEuropean Adhesives and Sealants Market2023-2028’, was ocially launched atthe 2023 European Adhesive & SealantConference and EXPO in Tarragona.The European Adhesives and SealantsMarket Report 2023-2028 gives detailedforecasts aiming at an accurate pictureof the market during this period. Thereport also provides indispensableinsights to help companies beer posionthemselves for success in today’s businessenvironment.Read Smithersarcle on howthe UK adhesivessector connuesgrowth despiteheadwinds onpage 14.
BASA membersare elibable forthe members ratefor the report.www.feica.eu/informaon-center/market-reports
7 BASA Bullen Issue 102 BASA Bullen Issue 102highlight how our industry’s products are crucial in a modern world and help create a more sustainable society. , the Associaon of the European Adhesive & Sealant Industry, launched a website on this day at www.internaonaladhesiveandsealantday.com. Kristel Ons, FEICA Secretary General said ‘Internaonal Adhesives and Sealants day aords an opportune occasion to showcase everything that could not exist without our incredible industry and to celebrate how it enables a more sustainable world. The adhesive and sealant industry is connuously innovang and developing technologies to support a growing world populaon to live a beer life and to use the planet’s resources responsibly and eciently. We hope that everyone will share our enthusiasm to put our amazing global industry in the spotlight today’. In Europe in parcular, the following are some examples how our industry supports the European Commission’s Goals: • Our industry’s adopon of digital Internaonal Adhesive & Sealant Day was globally recognised at the 2022 World Adhesive and Sealant Conference (WAC) to be celebrated each year on 29 September. It is an ideal opportunity to technologies that are revoluonising the way businesses operate, seng new standards for eciency, producvity, and innovaon, as well as the importance of assembling electronic devices "International Adhesives and Sealants day affords an opportune occasion to showcase everything that could not exist without our incredible industry and to celebrate how it enables a more sustainable world."• Windmills, solar panels, baeries, the insulaon of buildings and light-weight vehicles (essenal for renewable energy and energy savings) • Medical and dental care, prostheses and masks (essenal for good health and well-being) • Products used for electrolysers to produce hydrogen, sustainable biogas and biomethane, for carbon capture and storage, and for power grids (essenal for products relang to the EU strategic Industries) • Water membranes and lters (essenal for clean water and sanitaon) • Reusable packaging (essenal for avoiding food waste) If you missed this press release, you can sll check out some of these highlighted at: www.internaonaladhesiveandsealantday.com/innovaons. For further informaon about FEICA, please visit their website www.feica.eu.
BASA Bullen Issue 102 BASA Bullen Issue 1028In July 2023 the European Commission published the proposed dra EU Toys Regulaon, which converts the exisng Toy Safety Direcve into a new Toy Safety Regulaon. The dra regulaon stems from a review of the Toys Direcve which was carried out in 2020 where it was idened that there was room to strengthen some of the rules. The new regulaon would repeal The Toys Direcve 2009/48/EC.The European Commission stated that “The evaluaon of the Toy Safety Direcve (TSD) (the Evaluaon) idened a number of deciencies in the TSD in ensuring a high level of protecon of children from possible risks in toys, and in parcular from risks posed by harmful chemicals. The Evaluaon also concluded that there remain many non-compliant and unsafe toys on the EU market. “The intenon of the new regulaon “should achieve a higher level of protecon of children from the most harmful substances and reduce the number of non-compliant and unsafe toys on the EU market.”The review idened some problems;• Insucient protecon of children from harmful chemicals • A high number of toys on the Union market do not comply with the Toy Safety Direcve and are unsafe • New risks in toys, from emerging digital technologies.Many of the suggested changes and the review are part of the chemical strategy for sustainability (CSS) which called for extending the so-called generic approach towards harmful chemicals (based on generic prevenve bans) to ensure that consumers, vulnerable groups and the natural environment are more consistently protected. In parcular, the CSS called for strengthening the Direcve with regard to protecon from the risks posed by the most harmful chemicals and with regard to possible combinaon eects of chemicals. The Direcve already contains a general prohibion on substances in toys that are carcinogenic, mutagenic or toxic for reproducon (CMRs). However, it does not refer to other substances of parcular concern, such as endocrine disruptors or substances aecng the immune, nervous or respiratory systems.Nitrosamines and nitrosable substances are prohibited in toys intended for use by children under 36 months or in other toys intended to be placed in the mouth where the migraon of those substances is equal to or higher than 0,01 mg/kg for nitrosamines and 0,1 mg/kg for nitrosable substances.The following limit values, in toys or components of toys or micro-structurally disnct parts of toys, shall not be exceeded:The review suggested a few key areas for change.• Policy opon 1a – minimum changes to the Direcve • Policy opon 1b – Improved protecon: generic bans of the most harmful substances with derogaons • Policy opon 1c – Maximum protecon: generic bans of the most harmful substances without derogaons• Policy opon 2a: extending third-party conformity assessment • Policy opon 2b: facilitaon of market surveillance through digitalisaon• Policy opon 2c: Extending third party conformity assessment and facilitaon of market surveillance through digitalisaonAnd the European Parliament calls on the Commission to revise the Direcve to: (i) strengthen the protecon of children against chemical risks; (ii) ensure that risks posed by internet-connected toys are addressed by EU law; and (iii) improve enforcement of the Direcve in parcular in relaon to online sales.The Regulaon applies to products which are for use in play by children under 14 years of age.Substances or mixtures classied in any of the following categories is prohibited:(a) carcinogenicity, germ cell mutagenicity or reproducve toxicity (CMR) category 1A, 1B or 2;(b) endocrine disrupon category 1 or 2;(c) specic target organ toxicity category 1, either in single exposure or in repeated exposure;(d) respiratory sensisaon category 1.Cosmec toys, such as play cosmecs for dolls, shall comply with the composional and labelling requirements laid down in Regulaon (EC) No 1223/2009.The following migraon limits, from toys, components of toys or micro-structurally disnct parts of toys, shall not be exceeded:
9BASA Bullen Issue 102 BASA Bullen Issue 102Toys shall not contain 58 fragranceallergens unless their presence in the toyis technically unavoidable under goodmanufacturing pracce and does notexceed 100 mg/kg. You can see the fulllist of these 58 fragrance allergens on the Health & Safety Working Group.The names of 71 fragrance allergens shallbe listed on the toy, on an axed label,on the packaging or in an accompanyingleaet, as well as in the product passport,if those allergens are added to a toy,where they are present in the toy or anycomponent thereof at concentraonsexceeding 100 mg/kg. You can also see the full list of these 71 fragrance allergens on the Health & Safety Working Group.The use of fragrances referred to in entries41 to 55 in the table in Part A, point 4,and of fragrances referred to in points 1to 10 in the table in point 1 of this Partshall be allowed in olfactory board games,cosmec kits and gustave games, underthe following condions:(a) the fragrances are clearly labelledon the packaging of the toy, and thepackaging contains the warning referredto in point 11 of Annex III;(b) where applicable, the resulngproducts made by the child inaccordance with the manufacturer’sinstrucons comply with Regulaon(EC) No 1223/2009; and(c) where applicable, the fragrancescomply with the relevant Unionlegislaon on food.Such olfactory board games, cosmec kitsand gustave games shall not be usedby children under 36 months and shallcomply with point 2 of Annex III.There are some permied uses for Nickel(carc 2) in toys and toy components madeof stainless steel and in toy componentswhich are intended to conduct an electriccurrent.There is a new requirement for digitalproduct passports, this replaces theexisng Declaraon of Conformity. All toys,including those sold online, are requiredto have a Digital Product Passport. Theregulaons specify the informaon thatmust be contained within the passport,the product passport shall;(a) correspond to a specic toy model;(b) state that compliance of the toywith the requirements set out in thisRegulaon and, in parcular, theessenal safety requirements, has beendemonstrated;(c) contain at least the informaon setout in Part I of Annex VI;(d) be up to date;(e) be available in the language orlanguages required by the MemberState where the toy is made availableon the market;(f) be accessible to consumers orother end-users, market surveillanceauthories, customs authories,noed bodies, the Commission andother economic operators;(g) be available for a period of 10 yearsaer the toy is placed on the market,also in cases of insolvency, a liquidaonor a cessaon of acvity in the Union ofthe economic operator that created theproduct passport;(h) be accessible through a data carrier;(i) full the specic and technicalrequirements laid down pursuant toparagraph 10.Arcle 5 of the regulaons has beenexpanded to include mental health risks.1. Toys shall only be placed on the marketif they comply with the essenal safetyrequirements which include the safetyrequirement set out in paragraph 2(the ‘general safety requirement’)and the safety requirements set outin Annex II (the ‘parcular safetyrequirements’).2. Toys shall not present a risk to thesafety or health of users or thirdpares, including the psychologicaland mental health, well-being andcognive development of children,when they are used as intendedor in a foreseeable way, bearingin mind the behaviour of children.When assessing the risk referred toin the rst subparagraph, the abilityof the users and, where appropriate,their supervisors shall be taken intoaccount. Where a toy is intended foruse by children under 36 months orby another specied age groups, theability of users in that specic agegroup shall be taken into account.3. Toys placed on the market shall complywith the essenal safety requirementsduring their foreseeable period of use.The dra proposed regulaon speciesthat toys that include baeries should bedesigned in such a way that the baeriesare dicult for children to access. Inaddion the baeries must comply withother relevant regulaons for exampleThe Regulaon on the registraon,evaluaon, authorisaon and restriconof chemicals (REACH) and the BaeriesDirecve.In order to help with challengessurrounding translaon the reviewsuggested replacing the word ‘Warning’by a generic pictogram. The report statesthat this would lead to simplicaon for the industry without compromising theprotecon of children. It would also lead to savings to the industry when producingthe labels but these savings cannot bequaned with precision.Without prejudice to the applicaon of theprovisions laid down in applicable Unionlegislaon on the classicaon, packagingand labelling of certain substances ormixtures, the instrucons for use oftoys containing inherently dangeroussubstances or mixtures shall bear awarning of the dangerous nature of thosesubstances or mixtures and an indicaonof the precauons to be taken by theuser in order to avoid hazards associatedwith them. These precauons shall bespecied concisely and shall relate to thetype of toy. The rst aid to be given in theevent of serious accidents resulng fromthe use of the relevant type of toy shallalso be menoned. It shall also be statedthat the toy is to be kept out of reach ofchildren under a certain age, which shallbe specied by the manufacturer.In addion to the instrucons referred toin the rst subparagraph, chemical toysshall bear the following warning on theirpackaging:‘Not suitable for children under …2 years.For use under adult supervision’.A transion period of 30 months hasbeen proposed. It would apply 30 monthsaer the date of entry into force of thisRegulaon. This would apply to all newtoys.The dra legislaon went through aneight-week feedback period which closedon 31st October 2023, details can befound here:hps://ec.europa.eu/info/law/beer-regulaon/have-your-say/iniaves/13164-Protecng-children-from-unsafe-toys-and-strengthening-the-Single-Market-revision-of-the-Toy-Safety-Direcve_enThe new regulaon will be evaluated aer5 years.If you place toys onto the market, carefullyreview the proposed regulaon and thenstart to prepare for the regulaon byreviewing your product porolio and thechemicals you use.
BASA Bullen Issue 102 BASA Bullen Issue 10210Over the past few years, there has been a notable surge in interest regarding Scope 3 reporng by companies. In fact, there was a 28% increase in Scope 3 categories disclosed to CDP in 2022, as compared to 2019. And the overwhelming majority (92%) of emissions disclosed by European companies in 2022 were Scope 3, with the use of sold products (57%) and purchased goods and services (17%) cited as companies’ key hotspots. For those not yet familiar with Scope 3, these are emissions that originate from acvies both upstream and downstream, involving suppliers, customers and other acvies. As opposed to Scope 1 and Scope 2 emissions, where companies have more direct inuence in assessing and reducing emissions, Scope 3 emissions present a unique challenge as they oen require collaboraon and data sharing with various enes or stakeholders in the value chain.As organisaons are increasingly recognising the signicance of Scope 3 emissions in their overall carbon footprint, noteworthy trends are emerging in climate-related commitments and carbon accounng. Let’s delve into some of these key trends shaping the Scope 3 landscape:It’s no secret that the urgency to address emissions is ramping up. As part of the quest for a more sustainable future, regulaons are increasingly coming into force that require organisaons to disclose their carbon footprints, with some enforcing the reporng of Scope 3 emissions.Take the Corporate Sustainability Reporng Direcve (CSRD) as an example. This regulaon will require all large enterprises that carry out business in the EU, including those based outside of the EU, to disclose their carbon footprint starng in 2024, covering Scope 3 emissions too. The proporon of global emissions covered by companies with a target including Scope 3 has more than doubled since 2019. This indicates a growing trend in corporaons preparing for regulatory requirements and recognising the importance of addressing their indirect emissions.In turn, this means that companies are seeking more granular and specic Scope 3 data to eecvely monitor their progress. However, a signicant challenge in seng robust Scope 3 targets lies in accessing high quality informaon from supply chains.To address this obstacle, carbon accounng tools are emerging to facilitate the collecon and monitoring of emissions data across the value chain. In fact, the global carbon accounng soware market size is projected to grow from $15.31 billion in 2023 to $64.39 billion by 2030.The reason behind this boom is the fact that automang carbon accounng makes tasks like data collecon, emissions tracking and analysis a lot more streamlined. Addionally, it enhances transparency, auditability and traceability for carbon reporng. Not to menon that the transformaonal insights oered by these tools oen leads to cost savings too, as the greatest sources of emissions are typically also sources of nancial ineciency. As companies are taking proacve measures to enhance transparency and due diligence by establishing value chain-wide carbon accounng pracces, many internaonal corporates are using Scope 3 reporng to engage with their supply chain. This means that, increasingly, companies are asking their suppliers to provide sustainability informaon, including carbon emissions.
11 BASA Bullen Issue 102 BASA Bullen Issue 102For example, beginning in 2024, Amazon is updang its Supply Chain Standards to require suppliers to share their carbon emissions data and set carbon goals. This is in parallel with Amazon's decarbonisation target to reach net zero by 2040, requiring it to reduce its carbon footprint across the entire business, including its vast global supply chain.Another example of retailers bolstering their Scope 3 is the recent collective initiative by eight of the UK’s biggest supermarkets, representing approximately 80% of the UK market, alongside WRAP and WWF. As a group, they will develop a consistent framework for the measurement and reporting of the retailer’s Scope 3 emissions. It is apparent that Scope 3 reporting is not a passing trend. Instead, it’s gaining momentum and recognition for the pivotal role it plays in avoiding the worst effects of climate change. As more and more companies find themselves under mounting pressure, not only from impending legislation but also from investors and key stakeholders, the announcement and implementation of Scope 3 commitments will rise in parallel. By staying at the forefront of carbon reporting trends, businesses that fall within these companies’ value chains can not only be prepared for what information they may have to disclose, but also position themselves as leaders in sustainability and boost their own long-term resilience. "We celebrate this amazing achievement due to our employee’s determinaon and due diligence. Thank you to all our employees for making safety a priority every single day!We encourage employees to connue to report all near misses to catch potenal accidents before they happen and ensure we connue this trend. "
BASA Bullen Issue 102 BASA Bullen Issue 10212I hope most of you have enjoyed a holiday. I see it as a me for reecon and the opportunity to rise above pressing, day to day, challenges. My three weeks in Pembrokeshire has given me the me and energy to reect on the current state of the UK, and elsewhere.The most commonly used word in the media is crisis. Crisis is dened as a me of intense diculty or danger. Parts of the Ukraine, central Africa, Western Canada, Florida, Libya, Morocco and Hawaii have all experienced weather-related crises over the past six weeks. But is there an economic crisis?There is no economic crisis; a more appropriate word would be malaise. There is a general feeling of unease although it is hard to pinpoint its cause. The UK and Germany, in parcular, are experiencing tolerable underperformance. Tolerable underperformance is best described as low or no real growth, with full employment.The latest revisions to UK GDP show that, since 2021, UK economic performance has been in line with the rest of Europe; not worse, as originally thought. But we should note that the revisions do not mean the man in the street is beer o. Wholesalers and food retailers made much greater prots than originally esmated. China’s underperformance is causing the same problem in Germany. Germany however, sll has a trade surplus of 4% of GDP which compares favourably to the UK’s 3.3% decit.The polics reect tolerable underperformance. There are shis le or right of centre across a range of countries. Ignoring the USA, these shis are unlikely to result in major changes in economic management. The UK is experiencing pey wrangling and a clash of cultures between young taxpayers and the old comfortably wealthy. There are growing numbers of the laer.Stagaon, a period of rising prices with lile or no real growth, is tolerable for the majority, parcularly if pensions and the minimum wage keep pace with inaon. If next year brings a coalion or a Labour Government, faces will change; hopefully there will be more energy and competence. However, don’t expect any major shis in economic policy.OCTOBER 2023 1ECONOMIC UPDATE OCTOBER 2023Inaon is falling across the globe due to the collapse in annual money supply growth rate from 14% to 1%. Inaon has reduced the purchasing power of exisng money by at least 10%. Populaons have less real spending power so real demand has fallen back from the end of the lockdown peaks. Supply and demand in a wide range of goods and services is beginning to balance out.The current danger is overkill due to a rigid inaon target of 2%. The USA sensibly has a exible inaon target; they now take an average over a number of years. It means that even if inaon is above 2%, the USA will reduce interest rates if growth stagnates. The UK has a target range of 1-3% but no averaging over me.Unfortunately, the UK Government has policised the seng of interest rates by the the Bank of England. It rstly blamed gas prices; now it blames the Bank for our inaon rate. The cause is actually generous furlough and business support during covid, nanced by new money from the Bank as requested by the Cabinet.Money Supply Growth in Major Advanced Economies
13 BASA Bullen Issue 102 BASA Bullen Issue 102I hope most of you have enjoyed a holiday. I see it as a me for reecon and the opportunity to rise above pressing, day to day, challenges. My three weeks in Pembrokeshire has given me the me and energy to reect on the current state of the UK, and elsewhere.The most commonly used word in the media is crisis. Crisis is dened as a me of intense diculty or danger. Parts of the Ukraine, central Africa, Western Canada, Florida, Libya, Morocco and Hawaii have all experienced weather-related crises over the past six weeks. But is there an economic crisis?There is no economic crisis; a more appropriate word would be malaise. There is a general feeling of unease although it is hard to pinpoint its cause. The UK and Germany, in parcular, are experiencing tolerable underperformance. Tolerable underperformance is best described as low or no real growth, with full employment.The latest revisions to UK GDP show that, since 2021, UK economic performance has been in line with the rest of Europe; not worse, as originally thought. But we should note that the revisions do not mean the man in the street is beer o. Wholesalers and food retailers made much greater prots than originally esmated. China’s underperformance is causing the same problem in Germany. Germany however, sll has a trade surplus of 4% of GDP which compares favourably to the UK’s 3.3% decit.The polics reect tolerable underperformance. There are shis le or right of centre across a range of countries. Ignoring the USA, these shis are unlikely to result in major changes in economic management. The UK is experiencing pey wrangling and a clash of cultures between young taxpayers and the old comfortably wealthy. There are growing numbers of the laer.Stagaon, a period of rising prices with lile or no real growth, is tolerable for the majority, parcularly if pensions and the minimum wage keep pace with inaon. If next year brings a coalion or a Labour Government, faces will change; hopefully there will be more energy and competence. However, don’t expect any major shis in economic policy.OCTOBER 2023 1ECONOMIC UPDATE OCTOBER 2023Inaon is falling across the globe due to the collapse in annual money supply growth rate from 14% to 1%. Inaon has reduced the purchasing power of exisng money by at least 10%. Populaons have less real spending power so real demand has fallen back from the end of the lockdown peaks. Supply and demand in a wide range of goods and services is beginning to balance out.The current danger is overkill due to a rigid inaon target of 2%. The USA sensibly has a exible inaon target; they now take an average over a number of years. It means that even if inaon is above 2%, the USA will reduce interest rates if growth stagnates. The UK has a target range of 1-3% but no averaging over me.Unfortunately, the UK Government has policised the seng of interest rates by the the Bank of England. It rstly blamed gas prices; now it blames the Bank for our inaon rate. The cause is actually generous furlough and business support during covid, nanced by new money from the Bank as requested by the Cabinet.Money Supply Growth in Major Advanced EconomiesThere is NO case at all to raise rates from the current level. There is a case to move to a more flexible target for inflation, but the PM has made the inflation target one of his five measures of leadership performance, even though it is completely out of his control! In fact, of his five targets, the only one within his control is stopping the boats. If the Bank of England raise rates further, we should expect a mild recession in an election year. So there is no need to raise interest rates beyond the current 5% unless wage awards still run in excess of 5%. However, regular pay in the first part of this year was up 7.2%. UK productivity is currently estimated at 1.3%. So arithmetically, we are looking at core inflation running at 5-6%. Therefore the 2% inflation rate target is unrealistic.Inflation will only fall to 2% in countries which enjoy productivity growth. In this, the USA leads. And most other countries lag. (see chart). As I have said in previous updates, unless productivity can be increased through automation, inflation control requires higher unemployment for all skill sets - a recession.This chart explains. The growth in private sector pay is running at 7% excluding bonuses. The UK services’ inflation rate is slightly lower. If productivity was growing at say 2%. inflation rate for services would be 5%.An important component of the surge in inaon was the rise in import prices as global energy and food costs soared with the outbreak of war in Ukraine. At one point last autumn, that price surge damaged our terms of trade and subtracted about 1.5 per cent from the our naonal income. The terms of trade is the dierence between import prices and export prices. If export prices are rising by more than import prices; the terms of trade are improving; conversely, if import prices are rising by more than export prices: the terms are deteriorang.However, the surge, which drove consumer price inaon to annual rates above 10 per cent, has now fully reversed. Indeed, the terms of trade are now slightly beer than they were at the beginning of 2022.Consequently, the rate of price increases is falling fast; consumer prices in the month of June rose at an annual rate below 2 per cent, and in July the CPI index fell by 0.4 per cent, due to a decline in energy prices.The UK suered an unavoidable loss of real income as import prices rose. If workers aempted to maintain their previous levels of real income, the result would be a wage spiral. This happened in the 1970s when the terms of trade deteriorated signicantly due to a quadrupling in the price of oil.Given the terms of trade recovery and no growth in money supply, there will not be a wage price spiral. Real wages are down 4.5 per cent since the beginning of 2022, having failed to keep pace with inaon. But companies have done well. The latest revisions to GDP are the largest we have seen. £44Bn added, due to actual prots being higher than esmated in the food retail and wholesale sector, plus more accurate data on health sector output. As the NHS provides 88% of UK health care output, it is clearly performing well. 85% of NHS output is now measured on an output basis, when formerly it was on an input basis. (i.e. how much was spent, rather than what was produced).OCTOBER 20232Growth in Private Sector Pay and Services InaonYou can read the rest of Roger Marn-Fagg's Economic Update under the Business Steering Commiee (BSC) WG.
BASA Bullen Issue 102 BASA Bullen Issue 10214The UK adhesives and sealants and industry is plong a future path to recovery. New exclusive data from market research specialist Smithers indicates that in 2023 it is sll the third largest market in Europe, with demand reaching a projected 421,700 tonnes, with a value of £1.30 billion (€1.50 billion). Published in FEICA’s European Adhesives and Sealants Market 2023-2028 [hps://www.feica.eu/information-center/market-reports] these data show adhesives account for £978.0 million or 75.4% of the market by value, and sealants £425 million 24.6%. The industry outlook is sll negavely impacted by broader economic factors. There was a slump in sales during the Covid pandemic, as many core end-use industries slowed or ground to a halt. This was only slightly ameliorated by increased demand from certain priority sectors, such as medical PPE and e-commerce packaging. Hopes of a swi recovery have been dashed by macroeconomic factors, including spiralling inaon, extra costs associated with Brexit, weak domesc consumer condence, and soaring energy input prices caused by the war in Ukraine. In 2023, the UK is only G7 country where the economy remains smaller in 2023 than it was before the pandemic.Smithers analysis tracks a route for the sector to return to posive growth in the near future, capitalising on evolving market opportunies and new technology demands. Sll with many issues unresolved this recovery will be slow, and fragile. Consumpon volumes are forecast to increase at a +0.5% compound annual growth rate for 2023-2028, reaching 476,600 tonnes in its nal year. Value will increase slightly faster, with a +1.0% CAGR forecast for value, with sealants slightly outperforming adhesives. In 2023, polymer dispersions and emulsions remain the most widely used adhesives in the UK. Smithers data show these represent 44.9% of contemporary naonal demand, by volume; and 29.7% by value. By tonnage hot melts are the second most widely used adhesive type, 18.2% market share; ahead of reacve (polymerising) adhesives, 15.9%. The laer have the best growth outlook through to 2028; and there will also be appreciable gains in the market share of adhesives made with natural polymers, such as starch, dextrin, casein, and latex. Paper and board applicaons – packaging, bookbinding, ssue manufacture, etc – connue to be largest user of adhesives in the UK. Packaging has beneed from the local popularity of e-commerce shopping over the past three years, with the country enjoying one of the highest rates of online delivery sales in Europe. This sector can reward innovaons, such as the development of adhesive tabs to enable easy opening and resealing, for returns, in the same container. Returns are most common in apparel segments. Long dependent on polyethylene mailers, many brands are now invesgang a transion to waterproof paper envelopes and mailer formats. Increasingly brands are calling for greater sustainability in home-delivery formats. This is placing a premium on adhesives formulated from natural ingredients, with several commercial suppliers now boasng 80% bio-based content in hot-melt grades. At the same me recyclability at end-of-life is increasingly of concern, and for adhesives that do not compromise recyclability of corrugated or other paper stocks when disposed of. A similar impetus in exible plasc packaging has prompted interest in opmised water-based blends that can debond eciently during processing in a material recovery facility. In October 2023, the UK joined the wider European trend in enforcing a ban on certain single-use plasc foodservice containers. This has smulated sales of alternave paperboard clamshells, cups, and trays, including those built with compostable hot-melt formulaons. In hygiene, wipes, and feminine hygiene goods, performance remains the most important consideraon, although the sector is sll looking for more sustainable soluons, including those that enable a transion to more bre-based components or reduce the volume of adhesive consumed. Consumer and DIY adhesive sales also performed well across the Covid pandemic. Home improvement remained one of the few pasmes possible during strict lockdown condions, and the widespread transion to home working saw many families add a home oce or extension. This peak is now tailing o and consumer/DIY products will have the slowest growth rate across the next ve years. The surge in natural gas prices that occurred following Russia’s invasion of Ukraine in 2022, has aected many industries that use adhesives. This has served to delay UK industrial recovery from Covid-19.From a technical perspecve, it has smulated further interest in formulaons with lower curing temperature, while some end-users are also invesng in technology that enables more precise deposion, like hot-melt stching, that can cut the overall volumes of adhesives required. In transportaon, uncertainty post-Brexit has raised quesons over the future of automove manufacture in the UK, exacerbated by global supply chain issues. Signicant government support has convinced several major car builders to locate new electric vehicle (EV) factories in the UK. With EVs weight is at a premium for all components to improve travelling range. This is reinforcing the trend to use more adhesives in place of other heavier bonding technology in a car’s chassis. Another potenally lucrave segment will be the development of high-performance adhesives and sealants for electric vehicle baeries. Similar issues have aected many assembly industries. UK manufacturing output saw a major drop, down -5.2% in 2020, followed by a surge in producon across 2021, +15.1%. This trajectory has not been sustained however, with another fall of -4.5% seen in 2022. Construcon has also largely recovered, but has a at outlook, with the wider macro-economic picture meaning there is lile public- or private-sector investment planned for the immediate future. BASA members receive the members rate on the FEICA report.
15 BASA Bullen Issue 102 BASA Bullen Issue 102Due to the highly interconnected nature of chemicals supply chains, the UK decision to leave the EU connues to have important implicaons for businesses. While imports into the EU and Northern Ireland need to be EU REACH compliant, chemicals manufactured and imported into Great Britain (GB) are subject to separate UK law. Registraon, authorisaon, SVHC communicaon and restricons remain key provisions under UK REACH. Although similar in structure, EU and UK REACH are implemented independently from each and other, bringing signicant challenges to businesses operang in both markets. In this short arcle, we provide an outline of some key points BASA members may need to consider when dealing with UK REACH.When the UK was part of the EU, companies that were using or distribung chemicals (on their own or in mixtures) in GB from EU registered sources were classed as downstream users or distributors under EU REACH. Since the entry into force of UK REACH, their role may have changed into REACH importer under UK REACH. This means that a registraon may be required for chemicals imported at 1 tonne or more in Great Britain, unless the registraon responsibility is taken over by a GB-only representave appointed by the chemical manufacturer or formulator based outside GB. A downstream user import nocaon (DUIN) scheme was put in place by the UK authories to help companies adapt to the change and connue to import unl a full registraon is required in due course. More recently, the registraon deadlines for substances beneng from the transional arrangements have been extended by 3 years to give me to government ocials to explore an alternave model of registraon to address concerns around the cost and complexity of duplicang registraons for the UK market. The new registraon deadlines are now set for 27 October 2026, 27 October 2028 and 27 October 2030, depending on the hazard prole of the substance and the tonnage band.As the market for chemical products is not stac, many of our subscribers regularly enquire about the regulatory implicaons of making changes to exisng supply chains or what acons should be taken if, for example, a company intends to start imporng specic chemicals or products for the rst me. In the rst case, it is important to note that UK REACH allows for a change of supplier in relaon to the downstream user nocaons, provided the new supplier is also covered by an EU REACH registraon. In the second scenario, if GB companies manufacture or import substances on their own or in mixtures for the rst me aer the end of the Brexit transion period and they establish that they have registraon obligaon, then a UK registraon is required prior to the manufacture or import of the substance into GB reaching 1 tonne per year. In this case, a downstream user nocaon (DUIN) does not apply. For substances that were previously registered under EU REACH, companies may however be able to defer the submission of the full registraon such that data sharing with other registrants can take place. Instrucons for the dossier submission are provided by the HSE to potenal registrants at the Inquiry stage.The rst step of any new REACH registraon is to submit an Arcle 26 Inquiry dossier. The same process applies both in the EU and in GB. An Inquiry dossier must idenfy the potenal registrant, their substance and the informaon they require on the intrinsic properes of the substance to complete their registraon dossier. Detailed analycal informaon must be included to prove the substance’s identy. With respect to polymers, it is their monomers and any other reagent used at more than 2% w/w in synthesis that need registraon if imported at over 1 tonne equivalent. In many cases, importers of polymers have been unable to obtain samples of the appropriate monomers and reagents to allow conrmatory analysis prior to registraon. Because of this, some applicants relied on purchased samples of these monomer substances to put through analysis to sasfy REACH validaon rules. Aer informaon checks with the HSE helpdesk, it has been suggested that it may prove more useful to provide analycal evidence that the imported material is a true polymer and to conrm that the monomers/reagents used are as expected through a correct understanding of the polymer. Checks for impuries (contaminants) are also important. This is a more pragmac way to start the registraon process for monomers and reagents as it avoids having to buy the (somemes very hazardous) substances from laboratory suppliers. If companies need to import polymers, REACHReady can advise on the best approach for analysis.As the UK regime works independently from EU REACH, some degree of divergence is inevitable and already happening. Whilst the candidate list, authorisaon and restricon lists have been carried over at the end of the transion period, and the same legal obligaons apply in GB as in the EU, the regulatory processes that lead to substances being added to these regulatory lists have been adapted to a GB-only context. Although no new substances have been subject to further regulatory controls in GB to date, we advise companies to closely monitor ongoing acvies around UK authories’ priories, which are sll informed by EU developments, as detailed in the UK Agency’s Annual Work Programme and communicated via the HSE REACH bullens. REACHReady’s regular technical alerts available to our Gold Subscribers can also help companies keeping track of public consultaons, calls for evidence and upcoming changes on specic substances both in the EU and in the UK.
BASA Bullen Issue 10216For all your UK and EU REACH, CLP and BPR needsHelpdesk Our experts answer your REACH, CLP and BPR queries via email or telephoneConsultancy Support at any stage of the compliance process – a service tailored to your needsTraining Providing training through a wide range of public workshops, bespoke training and consultancy servicesMatchmaker Finding you trusted service providers to help you comply with REACH, CLP and the BPRA wholly-owned subsidiary of the Chemical Industries Association, REACHReady offers a condential, cost-effective service providing you with information and guidance on what you need to do to comply with UK and EU REACH, CLP and the Biocidal Products Regulation.With a current global membership of over 6,500 subscribers, we support people working at all stages of the supply chain and in a diverse range of industry sectors. Discover how we can help you – nd us online, email enquiries@reachready.co.uk or phone 020 7901 1444 today!REACHReady Gold Membership gives you:• Access to a specialist-staffedHelpdesk• Up to an hour of freeconsultancy for newsubscribers• 20% discount on publicseminars, training andworkshops… and morewww.cia.org.uk/reachreadyContact your Trade Association or REACHReady to apply for your REACHReady Gold membership at a 25% discounted rate!