ECHA

The Danish guidance targets those companies who market products for businesses or consumers. It primarily aims to help industry and retailers to phase out the four phthalates (DEHP, BBP, DBP and DIBP), which are currently on the REACH Authorisation List before the national ban takes effect in 2015, but also has a more general purpose, which makes it useful for phasing out other phthalates not yet subject to authorisation.

The guidance helps Danish importers and foreign exporters to identify whether there are phthalates of concern in the articles they are buying or selling. It also informs companies about the requirements they must meet if they wish to market these articles, how to engage in dialogue with their suppliers and how to start assessing whether these chemicals can be replaced.

Henrik Søren Larsen. Image: Danish EPA.

"We issued a national restriction on the four phthalates in consumer products in 2012. The ban was initially supposed to take effect in December 2013. However, we realised that these chemicals are used in so many different products and applications that it would be challenging to stop using them with such short notice, especially for importers. Therefore, we decided to delay the ban and launch a series of initiatives to help companies. This guidance is one of those initiatives," says Henrik Søren Larsen, Head of the Chemicals Division at the Danish Environmental Protection Agency.

The Danish EPA started analysing the problems industry and retailers have in replacing the four phthalates. "The issues identified include the timing of the ban, definitions of indoor and outdoor use, definitions of placing on the market, complex articles such as electronic equipment, and the availability of spare parts," Mr Larsen says.

Industry has been active in discussions together with the authorities on how to promote the replacement of the phthalates in the whole EU.

"We have thought about whether voluntary labelling or claims could be a way of promoting substitution and what the legal challenges are for companies that want to claim that their products are phthalate-free. Clearly, care should be taken to avoid unwarranted 'green washing'."

Denmark active in green technologies

In addition to their activities on phthalates, the Danish authorities have been driving for safer chemicals for many years.

"We have a national programme called the Development and Demonstration of Green Technologies. Part of this programme – which is broader than just chemicals – supports substitution efforts by companies. We focus particularly on the development of concrete products, such as alternatives to lead in fishing gear, non-fluorinated textiles or identifying suitable alternatives to substances on the REACH Candidate List, for example NMP and DMAC," Henrik Søren Larsen says.

The Danish EPA supports initiatives that promote or ease substitution, such as the development and access to QSAR tools or guidance on how to manage SVHC obligations.

"Last year, our government and the parliament agreed on a new four-year plan on chemicals. One of the new actions is to establish a facility to support the substitution of hazardous chemicals. We are currently scoping out the details of such a facility and expect that it will be up and running this summer," Mr Larsen highlights.

Consumer campaigns are another area where Denmark can be considered as a forerunner in Europe. "We are assessing our consumer articles regularly, and are launching information campaigns towards the general public as a result. We have had, for example, a campaign for pregnant women and a campaign for parents and grandparents of two-year olds, where we included a recommendation to be careful with soft PVC to avoid phthalates that may harm the reproductive system".

Danish Business guidance on phthalates. Image: Danish EPA.

Further information:

• Business guidance on phthalates (in English)
• Danish strategy on phthalates

Consumer campaigns in Denmark:

• Campaign for pregnant women
• Leaflet
• Toddler campaign towards parents and grandparents – leaflet
• Advice for children up to six-years old
• Campaign for handymen (in Danish)

Examples of substitution:

Companies win by substituting hazardous chemicals (video)

Did you know?   Phthalates are widely used as plasticisers to make plastic flexible. Some phthalates are classified as harmful to reproduction and included in the Candidate List under REACH. These are DEHP, BBP, DBP, DIBP, DMEP, DIHP, DHNUP, DPP, n-pentyl-isopentylphthalate and di-isopentylphthalate. Of these, DEHP, BBP, DBP and DIBP are subject to authorisation and cannot be used without permission from 21 February 2015 onwards.   Seven phthalates are also included in the Community rolling action plan (CoRAP) 2012-2104 for substance evaluation. Denmark is evaluating five of them.   In 2011, Denmark proposed to restrict the use of DEHP, BBP, DBP and DIBP in consumer articles in the EU. ECHA's Risk Assessment Committee, however, concluded that the "available data does not indicate that there is currently a risk from combined exposure to the four phthalates" and did not support the restriction. In its opinion, RAC pointed out that the existing regulatory measures and the consequential reduction in use would already reduce exposure.   The national ban for the four phthalates in consumer articles takes effect in Denmark in 2015.   A recent survey of 13 Danish associations and 39 companies concerning the replacement of the four phthalates shows that in most PVC-containing products, it would be technically possible to replace phthalates with other types of plasticisers. In many cases, it will even be possible to use other types of plastics without any plasticisers.   However, manufacturers and importers of electronic products will face problems as there are still applications, where the development of alternative components has not yet been finished. There are also technical challenges in terms of temperature resistance and flexibility of PVC-containing components.   The survey also notes that international brand manufacturers will not change their products to comply with specific national regulation. This means that there may be difficulties in relation to supply of products from international brands and spare parts for products already on the market after the implementation of the Danish phthalate regulation. Survey report (summary in English)

Interview by Hanna-Kaisa Torkkeli