Comments on ECHA’s Draft 7th Recommendation for Sodium perborate, perboric acid, sodium salt (EC number: 239-172-9; 234-390-0) and references to responses

The present document compiles the comments received during the public consultation on the draft 7th recommendation for inclusion of substances in Annex XIV of REACH for Sodium perborate, perboric acid, sodium salt (EC number: 239-172-9; 234-390-0). The public consultation took place between 18 November 2015 and 18 February 2016

For each of the comments there is also a reference to specific section(s) of a document containing the responses to comments (“Response document”, available at https://echa.europa.eu/documents/10162/13640/7th_recom_respdoc_perborates_en.pdf). The responses in the Response document are arranged by thematic block and level of information (see more detailed explanations at the beginning of that document).

Public version	

Content
	
I - General comments on the recommendation to include the substance in Annex XIV
II - Transitional arrangements. Comments on the proposed dates
III - Comments on uses that should be exempted from authorisation, including reasons for that

I - General comments on the recommendation to include the substance in Annex XIV
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3056
2016/02/02	Norway,
Member State	The Norwegian CA supports the prioritisation of Sodium perborate; perboric acid, sodium salt for inclusion in Annex XIV.

In general, the Norwegian CA supports grouping of substances of very high concern to avoid substitution with substances with similar properties within the same use categories.
	Thank you for your opinion.	
				
3074
2016/02/11	ChemSec,
International NGO,
Sweden	ChemSec supports the inclusion of this substance on Annex 14	Thank you for your opinion.	
				
3086
2016/02/16	PBS REACH Consortium,
Other contributor,
Slovenia	Comments you can find in attached document	A.1.5. Aspects not considered in ECHA's prioritisation
A.1.5.4. Control of risks
A.2.1. Disputing the volume score, claiming that the volume figures used for prioritisation are outdated
A.2.3. Use as bleaching agent in detergents and cleaning products already regulated by Annex XVII and therefore authorisation not relevant
A.2.4. ECHA should not proceed with recommending the perborates as long as 6th recommendation (including borates) is not concluded
A.2.5. Disputing harmonised classification
A.2.7. Claim that the socio-economic impact of inclusion of the substance in Annex XIV would be very high and result in a high burden for industry
Thank you for your opinion.	
		3086_Comments on public consultation on 7th draft recommendation for PBS_022016.pdf

3099
2016/02/17	Evonik Treibacher GmbH,
Company,
Austria		See responses referred to in comment #3086 (PBS Reach Consortium).	
		3099_SKOP1616021709500.pdf

3123
2016/02/17	Belinka Perkemija d.o.o.,
Company,
Slovenia	Please find it in attachemnt	See responses referred to in comment #3086 (PBS Reach Consortium).	
		3123_Comments on public consultation on 7th draft recommendation for PBS_022016.pdf

3173
2016/02/18	European Borates Association,
Industry or trade association,
Belgium	See attachment enclosed	A.2.2. Limited interchangeability/ grouping with boron compounds
A.2.3. Use as bleaching agent in detergents and cleaning products already regulated by Annex XVII and therefore authorisation not relevant	
		3173_EBA comments on Sodium perborates_18-02-2016.pdf

II - Transitional arrangements. Comments on the proposed dates
No comment. 

III - Comments on uses that should be exempted from authorisation, including reasons for that
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3074
2016/02/11	ChemSec,
International NGO,
Sweden	Following the intentions of REACH, socio-economic information should not play a role in the inclusion of substances on the authorisation list. The availability of alternatives as well as socio-economic implications should only be taken into account when companies apply for authorisation and for specific uses.
Information about how well industries using SVHCs are doing today and how much they will loose if a SVHC is added to annex XIV is of no use if there is not anything to compare with, the economic consequences and benefits for producers and users of alternatives and economic consequences of innovative industries using totally different techniques which all clearly would benefit from an annex XIV listing.
ChemSec calls on the Commission to focus more on getting economic information from producers and users of alternatives in order to get a more balanced picture of the socio-economic effects of adding SVHCs to annex XIV.
ChemSec will release a new report on the 23:d of February on this specific issue. The report is called “The bigger picture, assessing economic aspects of substitution”. We hope this report will provide a larger understanding on what aspects needs to be look at to make a solid economic assessment of substitution and regulation.
Moreover, lack of alternatives is not an incentive for not putting a substance on annex XIV. But lack of alternatives could give a rough indication on how many applications for authorisation ECHA will get for a specific substance.
	A.2.6. Socio-economic information and availability of alternatives should not play a role in the inclusion of substances in Annex XIV / Call on COM when and which socio-economic aspects to consider