BASA Bulletin Issue 102 : simplebooklet.com

Issue 102 November 2023INFORMED COMMENT FROM THE BRITISH ADHESIVES & SEALANTS ASSOCIATIONBulletinRead xtonnes' arcle about carbon accounng and how it can help your business stay ahead of the curve.10The deadline is fast approaching, read the arcle from BASA's Regulatory Ocer Caroline Raine on how we can help you make these nocaons.Read about the EU Dra Toy Safety Regulaon 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 bullens for all the delegates to catch up on the work that has been going on. Sports day was well aended by the shoong cohort, and although the number of golfers were a lile down on previous year, they sll 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 signicant challenge for all of us to stay on top of the dual regulatory schemes we now nd ourselves exposed to, and we are starng to see more fallout from Brexit in terms of goods being held up by addional 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 cricised 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 enty to take care of EU REACH obligaons. This potenally leaves BASA members exporng 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 declaraons to try to help members navigate this complex situaon. In August this year the Brish 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. Potenally 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 benet from the Trade and Cooperaon Agreement (TCA) zero tari, businesses must show the origin of their goods. A product qualies as ‘originang’, if it is ‘wholly obtained’ in the UK and EU or has been substanally transformed in one or both markets. As rules of origin are product-specic and compliance can be onerous, it is hoped that the import controls do not cause unexpected issues next year. Please connue to let us know of any specic problems so that we can look to help.We connue to work with the other UK Chemical Associaons to push for government to rethink the current UKREACH regulaon, and the whole issue of UKCA marking of Construcon Products connues to be hugely challenging. We are trying to develop some addional guidance documents in relaon to UKCA marking against a European Assessment Document (EAD) and connue to engage with DLUHC to understand what their real intenons are in respect of future UK Construcon Products Regulaons. Will the current Government actually try to pass new legislaon to enforce the intended date to cease recognion of CE marking (30/6/2025) before the general elecon 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 condions for business are not easy at present but try to support the Associaon 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

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BASA Bullen Issue 102 BASA Bullen Issue 1022For 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 promoon • Publicity in the BASA Bullen • A one page advert in the 2024 BASA Members Handbook • Table for 8 aendeesThere 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 fesvity.The ISO meeng this year took place on 27th and 28th September in Paris and was aended by representaves 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 commiee also resolved to start a new work item to develop a classicaon standard for Sanitary Sealants, incorporang 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 “Classicaon 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 connue to work on Aesthec Issues through WG10, where a dra will be published, some further work on Paint Compability, and also WG1 “UV Inuence” will be reacvated to revise ISO 11431 in the next 24 months. We have an urgent request for addional UK parcipants for ISO TC 59 SC8, parcularly to stand as an expert for WG25 Sanitary Sealants. The next meeng is in October 2024 in Japan.

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3 BASA Bullen Issue 102 BASA Bullen Issue 102This issue of the BASA Bullen 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 meanme, technology has come to the rescue of our technical work, even increasing eecveness and cost eciency, and broadening our reach and accessibility for the technical sta of our members. All our regular working group and commiee meengs 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 substute for in person meengs to build relaonships, so this format will connue at least once each year.The technical work we undertake remains at the heart of the associaon 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 standardisaon issues both in UK/GB and EU via FEICA.Jim Palmer, Technical Ocer, J P ConsultancyAs predicted our workload has been dramacally increased by the exit from the EU as we now have twice the number of legislave processes to follow. However, our redened reciprocal relaonship 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 informaon for members and is being connuously developed to improve accessibility. An issues map, which links all the up-to-date informaon on the many key issues, supplements and collates the regular working group posngs, which are also noed on a weekly basis to subscribing members.If you aended the Open Industry Forum on 2nd November, you will have read the latest situaon on the hoest issues on the working poster displays, which are summaries of the web pages on the web site. If you weren’t able to aend, then you missed a great day! I will comment on just a couple of key topics:   In Europe following a prolonged consultaon the EC has chosen to enhance the CPR to meet their objecve of a single market for construcon 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 crical products only as indicated by the building safety bill. Consequently, rumours abound that recognion of CE marking in UK may connue indenitely, especially in view of the lack of approved bodies to carry out the necessary test work. Cessaon of the recognion of CE marking in GB connues to a stated government aim but this cannot happen unl actual legislaon is brought forward. Mutual recognion is the only real answer to avoiding excessive repeat tesng. Mutual recognion agreements already exist between EU and other world bodies so why not between EU and UK?In UK the plasc packaging tax has driven the change to packaging that contains minimum 30% recycled material to avoid the tax. However, the new Collecon of Packaging Reform (CPR) reporng requirements are very complicated, and the implementaon has had to be delayed pending further consultaon. The intenon is for brand owners to fund the collecon and recycling cost of local government for household waste and the current classicaon system defaults packaging to ‘household waste’ unless other routes can be proven.Addionally, the divergent approaches around Europe to meet the aims of Extended Producer Responsibility regulaon is a potenal 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 regulaons and standardisaon. The me commitment is a maer of personal choice but can be minimal and those who parcipate fully nd it a great contribuon 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 Shoong Ground, Shropshire

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BASA Bullen Issue 102 BASA Bullen Issue 1024The Industrial use deadline is looming (1stJanuary 2024). Importers and downstreamusers of industrial use only mixturesneed to comply with the harmonisedinformaon requirements outlined inAnnex VIII to (EC) No 1272/2008 onclassicaon, labelling and packaging(CLP) of substances and mixtures andsubmit a poison centre nocaon 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 noed vianaonal submission systems before the2024 compliance date, it may benetfrom the transional period unl 1January 2025. This means that aer thisdate, all nocaons, regardless of theuse type, will need to be noed 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 nocaon (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/cloudplaorm 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 informaon and on thelabel or, in some cases, the packaging ofthe products that contain a hazardousmixture.More informaon on Northern Irelandand Poison centres can be found on theGOV UK website here:www.gov.uk/guidance/subming-chemicals-informaon-to-the-naonal-poisons-informaon-service           www.eventcreate.com/e/pcworkshop

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5BASA Bullen Issue 102 BASA Bullen Issue 102The EU taxonomy is a cornerstone of theEU’s sustainable nance framework andan important market transparency tool. Ithelps direct investments to the economicacvies most needed for the transion,in line with the European Green Dealobjecves.The taxonomy is a classicaon systemthat denes criteria for economic acviesthat are aligned with a net zero trajectoryby 2050 and the broader environmentalgoals other than climate.So eecvely it is a classicaonframework that determines whetheran economic acvity is environmentallysustainable and under EU legislaon,“large” EU companies will soon need toreport on their taxonomy “alignment”as part of their mandatory sustainabilitydisclosures.So very simply, this means reporngon the extent to which the acvity oftheir business corresponds to whatthe EU views as “environmentallysustainable”. Unfortunately this will catcha lot of large subsidiaries of US and otherinternaonal businesses and it is likelyto be a complicated exercise for manybusinesses, and one that they have nothad to undergo before.The Taxonomy Regulaon entered intoforce on 12 July 2020. It establishes thebasis for the EU taxonomy by sengout the 4 overarching condions that aneconomic acvity must meet to qualify asenvironmentally sustainable.Under the Taxonomy Regulaon, theCommission had to come up with theactual list of environmentally sustainableacvies by dening technical screeningcriteria for each environmental objecvethrough delegated and implemenng acts.The Commission created an educaonaland user-friendly website oering aseries of online tools to help usersbeer understand the EU taxonomy in asimple and praccal manner, ulmatelyfacilitang its implementaon andsupporng companies in their reporngobligaons.       : a visual representaon of sectors, acviesand criteria included in the EUTaxonomy delegated acts   : a step-by-step guide on reporng obligaons  : an overview of quesons 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:hps://ec.europa.eu/sustainable-nance-taxonomy/Synthomer plc are pleased toannounce they have receivedInternaonal Sustainability andCarbon Cercaon system (ISCC)PLUS cercaon. ISCC PLUScercaon is an internaonallyrecognised sustainabilitycercaon which veries thetraceability of incoming andoutgoing sustainable materialalong the value chain.Synthomer plc has been ceredas a trader with storage whichmeans Synthomer is able to buy,store and trade ISCC ceredproducts.This is an important milestone forSynthomer as it enables divisionsto pursue site specic cercaonwhich will put us in a good posionto oer ISCC cered sustainableproducts to customers using themass balance approach. ISCCcered raw materials such asButyl Acrylate, Gum Rosin, C5,Styrene, Butadiene, Acrylonitrileare in scope for site speciccercaon.The cercate is available on theirwebsite here:www.synthomer.com/about-us/cercaons/

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BASA Bullen Issue 102 BASA Bullen Issue 1026The FEICA 2023 European Adhesive& Sealant Conference and EXPO tookplace at the PortAventura ConvenonCentre in Tarragona, Spain, from 13 to15 September 2023 and was aended 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 DevelopmentCommiee, Avery Dennison• Prepare your porolio for upcoming substancerestricons 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 opportunies for packaging adhesives by ElizabethStaab, Chair of the FEICA Sustainability& Recycling of Adhesives in Paper &Packaging Applicaons TTF, H.B. FullerThe 2024 FEICA Conference & EXPOwill be held at Noordwijkerhout in theNetherlands, from 11 to 13 September2024. Registraon will open at thebeginning of 2024, so SAVE THE DATE!You can read more on this year'sconference in the forthcoming edion ofFEICA CONNECT, out in November.The market study programme, tled ‘TheEuropean Adhesives and Sealants Market2023-2028’, was ocially 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 beer posionthemselves for success in today’s businessenvironment.Read Smithersarcle on howthe UK adhesivessector connuesgrowth despiteheadwinds onpage 14.
BASA membersare elibable forthe members ratefor the report.www.feica.eu/informaon-center/market-reports

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7 BASA Bullen Issue 102 BASA Bullen Issue 102highlight how our industry’s products are crucial in a modern world and help create a more sustainable society. , the Associaon of the European Adhesive & Sealant Industry, launched a website on this day at www.internaonaladhesiveandsealantday.com. Kristel Ons, FEICA Secretary General said ‘Internaonal Adhesives and Sealants day aords 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 connuously innovang and developing technologies to support a growing world populaon to live a beer life and to use the planet’s resources responsibly and eciently. We hope that everyone will share our enthusiasm to put our amazing global industry in the spotlight today’. In Europe in parcular, the following are some examples how our industry supports the European Commission’s Goals: • Our industry’s adopon of digital      Internaonal 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 revoluonising the way businesses operate, seng new standards for eciency, producvity, and innovaon, 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, baeries, the insulaon of buildings and light-weight vehicles (essenal for renewable energy and energy savings) • Medical and dental care, prostheses and masks (essenal 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 (essenal for products relang to the EU strategic Industries) • Water membranes and lters (essenal for clean water and sanitaon) • Reusable packaging (essenal for avoiding food waste) If you missed this press release, you can sll check out some of these highlighted at: www.internaonaladhesiveandsealantday.com/innovaons. For further informaon about FEICA, please visit their website www.feica.eu.

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BASA Bullen Issue 102 BASA Bullen Issue 1028In July 2023 the European Commission published the proposed dra EU Toys Regulaon, which converts the exisng Toy Safety Direcve into a new Toy Safety Regulaon. The dra regulaon stems from a review of the Toys Direcve which was carried out in 2020 where it was idened that there was room to strengthen some of the rules. The new regulaon would repeal The Toys Direcve 2009/48/EC.The European Commission stated that “The evaluaon of the Toy Safety Direcve (TSD) (the Evaluaon) idened a number of deciencies in the TSD in ensuring a high level of protecon of children from possible risks in toys, and in parcular from risks posed by harmful chemicals. The Evaluaon also concluded that there remain many non-compliant and unsafe toys on the EU market. “The intenon of the new regulaon “should achieve a higher level of protecon of children from the most harmful substances and reduce the number of non-compliant and unsafe toys on the EU market.”The review idened some problems;• Insucient protecon of children from harmful chemicals • A high number of toys on the Union market do not comply with the Toy Safety Direcve 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 prevenve bans) to ensure that consumers, vulnerable groups and the natural environment are more consistently protected. In parcular, the CSS called for strengthening the Direcve with regard to protecon from the risks posed by the most harmful chemicals and with regard to possible combinaon eects of chemicals. The Direcve already contains a general prohibion on substances in toys that are carcinogenic, mutagenic or toxic for reproducon (CMRs). However, it does not refer to other substances of parcular concern, such as endocrine disruptors or substances aecng 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 migraon 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 disnct parts of toys, shall not be exceeded:The review suggested a few key areas for change.• Policy opon 1a – minimum changes to the Direcve • Policy opon 1b – Improved protecon: generic bans of the most harmful substances with derogaons • Policy opon 1c – Maximum protecon: generic bans of the most harmful substances without derogaons• Policy opon 2a: extending third-party conformity assessment • Policy opon 2b: facilitaon of market surveillance through digitalisaon• Policy opon 2c: Extending third party conformity assessment and facilitaon of market surveillance through digitalisaonAnd the European Parliament calls on the Commission to revise the Direcve to: (i) strengthen the protecon 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 Direcve in parcular in relaon to online sales.The Regulaon applies to products which are for use in play by children under 14 years of age.Substances or mixtures classied in any of the following categories is prohibited:(a) carcinogenicity, germ cell mutagenicity or reproducve toxicity (CMR) category 1A, 1B or 2;(b) endocrine disrupon category 1 or 2;(c) specic target organ toxicity category 1, either in single exposure or in repeated exposure;(d) respiratory sensisaon category 1.Cosmec toys, such as play cosmecs for dolls, shall comply with the composional and labelling requirements laid down in Regulaon (EC) No 1223/2009.The following migraon limits, from toys, components of toys or micro-structurally disnct parts of toys, shall not be exceeded:

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9BASA Bullen Issue 102 BASA Bullen Issue 102Toys shall not contain 58 fragranceallergens unless their presence in the toyis technically unavoidable under goodmanufacturing pracce 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 axed label,on the packaging or in an accompanyingleaet, 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 concentraonsexceeding 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,cosmec kits and gustave games, underthe following condions:(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 resulngproducts made by the child inaccordance with the manufacturer’sinstrucons comply with Regulaon(EC) No 1223/2009; and(c) where applicable, the fragrancescomply with the relevant Unionlegislaon on food.Such olfactory board games, cosmec kitsand gustave games shall not be usedby children under 36 months and shallcomply with point 2 of Annex III.There are some permied 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 theexisng Declaraon of Conformity. All toys,including those sold online, are requiredto have a Digital Product Passport. Theregulaons specify the informaon thatmust be contained within the passport,the product passport shall;(a) correspond to a specic toy model;(b) state that compliance of the toywith the requirements set out in thisRegulaon and, in parcular, theessenal safety requirements, has beendemonstrated;(c) contain at least the informaon 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 surveillanceauthories, customs authories,noed bodies, the Commission andother economic operators;(g) be available for a period of 10 yearsaer the toy is placed on the market,also in cases of insolvency, a liquidaonor a cessaon of acvity in the Union ofthe economic operator that created theproduct passport;(h) be accessible through a data carrier;(i) full the specic and technicalrequirements laid down pursuant toparagraph 10.Arcle 5 of the regulaons has beenexpanded to include mental health risks.1. Toys shall only be placed on the marketif they comply with the essenal safetyrequirements which include the safetyrequirement set out in paragraph 2(the ‘general safety requirement’)and the safety requirements set outin Annex II (the ‘parcular safetyrequirements’).2. Toys shall not present a risk to thesafety or health of users or thirdpares, including the psychologicaland mental health, well-being andcognive 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 specied age groups, theability of users in that specic agegroup shall be taken into account.3. Toys placed on the market shall complywith the essenal safety requirementsduring their foreseeable period of use.The dra proposed regulaon speciesthat toys that include baeries should bedesigned in such a way that the baeriesare dicult for children to access. Inaddion the baeries must comply withother relevant regulaons for exampleThe Regulaon on the registraon,evaluaon, authorisaon and restriconof chemicals (REACH) and the BaeriesDirecve.In order to help with challengessurrounding translaon the reviewsuggested replacing the word ‘Warning’by a generic pictogram. The report statesthat this would lead to simplicaon for the industry without compromising theprotecon of children. It would also lead to savings to the industry when producingthe labels but these savings cannot bequaned with precision.Without prejudice to the applicaon of theprovisions laid down in applicable Unionlegislaon on the classicaon, packagingand labelling of certain substances ormixtures, the instrucons for use oftoys containing inherently dangeroussubstances or mixtures shall bear awarning of the dangerous nature of thosesubstances or mixtures and an indicaonof the precauons to be taken by theuser in order to avoid hazards associatedwith them. These precauons shall bespecied concisely and shall relate to thetype of toy. The rst aid to be given in theevent of serious accidents resulng fromthe use of the relevant type of toy shallalso be menoned. It shall also be statedthat the toy is to be kept out of reach ofchildren under a certain age, which shallbe specied by the manufacturer.In addion to the instrucons 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 transion period of 30 months hasbeen proposed. It would apply 30 monthsaer the date of entry into force of thisRegulaon. This would apply to all newtoys.The dra legislaon went through aneight-week feedback period which closedon 31st October 2023, details can befound here:hps://ec.europa.eu/info/law/beer-regulaon/have-your-say/iniaves/13164-Protecng-children-from-unsafe-toys-and-strengthening-the-Single-Market-revision-of-the-Toy-Safety-Direcve_enThe new regulaon will be evaluated aer5 years.If you place toys onto the market, carefullyreview the proposed regulaon and thenstart to prepare for the regulaon byreviewing your product porolio and thechemicals you use.

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BASA Bullen Issue 102 BASA Bullen Issue 10210Over the past few years, there has been a notable surge in interest regarding Scope 3 reporng 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 acvies both upstream and downstream, involving suppliers, customers and other acvies. As opposed to Scope 1 and Scope 2 emissions, where companies have more direct inuence in assessing and reducing emissions, Scope 3 emissions present a unique challenge as they oen require collaboraon and data sharing with various enes or stakeholders in the value chain.As organisaons are increasingly recognising the signicance of Scope 3 emissions in their overall carbon footprint, noteworthy trends are emerging in climate-related commitments and carbon accounng. 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, regulaons are increasingly coming into force that require organisaons to disclose their carbon footprints, with some enforcing the reporng of Scope 3 emissions.Take the Corporate Sustainability Reporng Direcve (CSRD) as an example. This regulaon will require all large enterprises that carry out business in the EU, including those based outside of the EU, to disclose their carbon footprint starng in 2024, covering Scope 3 emissions too.     The proporon of global emissions covered by companies with a target including Scope 3 has more than doubled since 2019. This indicates a growing trend in corporaons preparing for regulatory requirements and recognising the importance of addressing their indirect emissions.In turn, this means that companies are seeking more granular and specic Scope 3 data to eecvely monitor their progress. However, a signicant challenge in seng robust Scope 3 targets lies in accessing high quality informaon from supply chains.To address this obstacle, carbon accounng tools are emerging to facilitate the collecon and monitoring of emissions data across the value chain. In fact, the global carbon accounng soware 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 automang carbon accounng makes tasks like data collecon, emissions tracking and analysis a lot more streamlined. Addionally, it enhances transparency, auditability and traceability for carbon reporng. Not to menon that the transformaonal insights oered by these tools oen leads to cost savings too, as the greatest sources of emissions are typically also sources of nancial ineciency.     As companies are taking proacve measures to enhance transparency and due diligence by establishing value chain-wide carbon accounng pracces, many internaonal corporates are using Scope 3 reporng to engage with their supply chain. This means that, increasingly, companies are asking their suppliers to provide sustainability informaon, including carbon emissions.

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11 BASA Bullen Issue 102 BASA Bullen Issue 102For example, beginning in 2024, Amazon is updang 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 determinaon and due diligence. Thank you to all our employees for making safety a priority every single day!We encourage employees to connue to report all near misses to catch potenal accidents before they happen and ensure we connue this trend. "

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BASA Bullen Issue 102 BASA Bullen Issue 10212I hope most of you have enjoyed a holiday. I see it as a me for reecon and the opportunity to rise above pressing, day to day, challenges. My three weeks in Pembrokeshire has given me the me and energy to reect on the current state of the UK, and elsewhere.The most commonly used word in the media is crisis. Crisis is dened as a me of intense diculty 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 parcular, 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 beer o. Wholesalers and food retailers made much greater prots than originally esmated. China’s underperformance is causing the same problem in Germany. Germany however, sll has a trade surplus of 4% of GDP which compares favourably to the UK’s 3.3% decit.The polics reect tolerable underperformance. There are shis le or right of centre across a range of countries. Ignoring the USA, these shis are unlikely to result in major changes in economic management. The UK is experiencing pey wrangling and a clash of cultures between young taxpayers and the old comfortably wealthy. There are growing numbers of the laer.Stagaon, a period of rising prices with lile or no real growth, is tolerable for the majority, parcularly if pensions and the minimum wage keep pace with inaon. If next year brings a coalion or a Labour Government, faces will change; hopefully there will be more energy and competence. However, don’t expect any major shis in economic policy.OCTOBER 2023 1ECONOMIC UPDATE OCTOBER 2023Inaon is falling across the globe due to the collapse in annual money supply growth rate from 14% to 1%. Inaon has reduced the purchasing power of exisng money by at least 10%. Populaons 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 inaon target of 2%. The USA sensibly has a exible inaon target; they now take an average over a number of years. It means that even if inaon 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 policised the seng of interest rates by the the Bank of England. It rstly blamed gas prices; now it blames the Bank for our inaon 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

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13 BASA Bullen Issue 102 BASA Bullen Issue 102I hope most of you have enjoyed a holiday. I see it as a me for reecon and the opportunity to rise above pressing, day to day, challenges. My three weeks in Pembrokeshire has given me the me and energy to reect on the current state of the UK, and elsewhere.The most commonly used word in the media is crisis. Crisis is dened as a me of intense diculty 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 parcular, 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 beer o. Wholesalers and food retailers made much greater prots than originally esmated. China’s underperformance is causing the same problem in Germany. Germany however, sll has a trade surplus of 4% of GDP which compares favourably to the UK’s 3.3% decit.The polics reect tolerable underperformance. There are shis le or right of centre across a range of countries. Ignoring the USA, these shis are unlikely to result in major changes in economic management. The UK is experiencing pey wrangling and a clash of cultures between young taxpayers and the old comfortably wealthy. There are growing numbers of the laer.Stagaon, a period of rising prices with lile or no real growth, is tolerable for the majority, parcularly if pensions and the minimum wage keep pace with inaon. If next year brings a coalion or a Labour Government, faces will change; hopefully there will be more energy and competence. However, don’t expect any major shis in economic policy.OCTOBER 2023 1ECONOMIC UPDATE OCTOBER 2023Inaon is falling across the globe due to the collapse in annual money supply growth rate from 14% to 1%. Inaon has reduced the purchasing power of exisng money by at least 10%. Populaons 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 inaon target of 2%. The USA sensibly has a exible inaon target; they now take an average over a number of years. It means that even if inaon 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 policised the seng of interest rates by the the Bank of England. It rstly blamed gas prices; now it blames the Bank for our inaon 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 inaon 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 naonal income. The terms of trade is the dierence 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 deteriorang.However, the surge, which drove consumer price inaon to annual rates above 10 per cent, has now fully reversed. Indeed, the terms of trade are now slightly beer 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 suered an unavoidable loss of real income as import prices rose. If workers aempted 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 signicantly 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 inaon. But companies have done well. The latest revisions to GDP are the largest we have seen. £44Bn added, due to actual prots being higher than esmated 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 InaonYou can read the rest of Roger Marn-Fagg's Economic Update under the Business Steering Commiee (BSC) WG.

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BASA Bullen Issue 102 BASA Bullen Issue 10214The UK adhesives and sealants and industry is plong a future path to recovery. New exclusive data from market research specialist Smithers indicates that in 2023 it is sll 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 [hps://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 sll negavely 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 inaon, extra costs associated with Brexit, weak domesc consumer condence, 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 posive growth in the near future, capitalising on evolving market opportunies and new technology demands. Sll with many issues unresolved this recovery will be slow, and fragile. Consumpon 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 naonal 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 reacve (polymerising) adhesives, 15.9%. The laer 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 applicaons – packaging, bookbinding, ssue manufacture, etc – connue to be largest user of adhesives in the UK. Packaging has beneed 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 innovaons, 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 invesgang a transion 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 boasng 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 plasc packaging has prompted interest in opmised water-based blends that can debond eciently 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 plasc foodservice containers. This has smulated sales of alternave paperboard clamshells, cups, and trays, including those built with compostable hot-melt formulaons. In hygiene, wipes, and feminine hygiene goods, performance remains the most important consideraon, although the sector is sll looking for more sustainable soluons, including those that enable a transion 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 pasmes possible during strict lockdown condions, and the widespread transion to home working saw many families add a home oce 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 aected many industries that use adhesives. This has served to delay UK industrial recovery from Covid-19.From a technical perspecve, it has smulated further interest in formulaons with lower curing temperature, while some end-users are also invesng in technology that enables more precise deposion, like hot-melt stching, that can cut the overall volumes of adhesives required. In transportaon, uncertainty post-Brexit has raised quesons over the future of automove manufacture in the UK, exacerbated by global supply chain issues. Signicant 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 potenally lucrave segment will be the development of high-performance adhesives and sealants for electric vehicle baeries. Similar issues have aected many assembly industries. UK manufacturing output saw a major drop, down -5.2% in 2020, followed by a surge in producon across 2021, +15.1%. This trajectory has not been sustained however, with another fall of -4.5% seen in 2022. Construcon has also largely recovered, but has a at outlook, with the wider macro-economic picture meaning there is lile public- or private-sector investment planned for the immediate future.                    BASA members receive the members rate on the FEICA report.

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15 BASA Bullen Issue 102 BASA Bullen Issue 102Due to the highly interconnected nature of chemicals supply chains, the UK decision to leave the EU connues to have important implicaons 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. Registraon, authorisaon, SVHC communicaon and restricons remain key provisions under UK REACH. Although similar in structure, EU and UK REACH are implemented independently from each and other, bringing signicant challenges to businesses operang in both markets. In this short arcle, 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 distribung 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 registraon may be required for chemicals imported at 1 tonne or more in Great Britain, unless the registraon responsibility is taken over by a GB-only representave appointed by the chemical manufacturer or formulator based outside GB. A downstream user import nocaon (DUIN) scheme was put in place by the UK authories to help companies adapt to the change and connue to import unl a full registraon is required in due course. More recently, the registraon deadlines for substances beneng from the transional arrangements have been extended by 3 years to give me to government ocials to explore an alternave model of registraon to address concerns around the cost and complexity of duplicang registraons for the UK market. The new registraon deadlines are now set for 27 October 2026, 27 October 2028 and 27 October 2030, depending on the hazard prole of the substance and the tonnage band.As the market for chemical products is not stac, many of our subscribers regularly enquire about the regulatory implicaons of making changes to exisng supply chains or what acons should be taken if, for example, a company intends to start imporng specic 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 relaon to the downstream user nocaons, provided the new supplier is also covered by an EU REACH registraon. In the second scenario, if GB companies manufacture or import substances on their own or in mixtures for the rst me aer the end of the Brexit transion period and they establish that they have registraon obligaon, then a UK registraon is required prior to the manufacture or import of the substance into GB reaching 1 tonne per year. In this case, a downstream user nocaon (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 registraon such that data sharing with other registrants can take place. Instrucons for the dossier submission are provided by the HSE to potenal registrants at the Inquiry stage.The rst step of any new REACH registraon is to submit an Arcle 26 Inquiry dossier. The same process applies both in the EU and in GB. An Inquiry dossier must idenfy the potenal registrant, their substance and the informaon they require on the intrinsic properes of the substance to complete their registraon dossier. Detailed analycal informaon must be included to prove the substance’s identy. With respect to polymers, it is their monomers and any other reagent used at more than 2% w/w in synthesis that need registraon 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 conrmatory analysis prior to registraon. Because of this, some applicants relied on purchased samples of these monomer substances to put through analysis to sasfy REACH validaon rules. Aer informaon checks with the HSE helpdesk, it has been suggested that it may prove more useful to provide analycal evidence that the imported material is a true polymer and to conrm that the monomers/reagents used are as expected through a correct understanding of the polymer. Checks for impuries (contaminants) are also important. This is a more pragmac way to start the registraon process for monomers and reagents as it avoids having to buy the (somemes 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, authorisaon and restricon lists have been carried over at the end of the transion period, and the same legal obligaons 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 acvies around UK authories’ priories, which are sll informed by EU developments, as detailed in the UK Agency’s Annual Work Programme and communicated via the HSE REACH bullens. REACHReady’s regular technical alerts available to our Gold Subscribers can also help companies keeping track of public consultaons, calls for evidence and upcoming changes on specic substances both in the EU and in the UK.

BASA Bulletin Issue 102

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