Chemical Policy

Background

Chemicals have a fundamental role in our modern society and daily life. They are present everywhere and are essential in many sectors, including health, housing, energy and mobility. Due to their importance and complexity, chemicals are regulated in the EU using different regulatory frameworks, and more than one legislation may apply to a single substance or mixture.

The European Union is a front-runner on chemicals policy and the Regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as well as the Regulation on the Classification, Labelling and Packaging of Substances and Mixtures (CLP) are two cornerstones of the European Chemical Policy. Both legislations aim to ensure a high level of protection of human health and the environment through better identification of the properties of chemicals and increased communication on their hazard across the supply chain, as well as the free circulation of substances on the internal market while enhancing innovation and competitiveness of the European Chemicals industry.

In addition to these two horizontal frameworks, specific groups of chemicals are covered by their own complementary legislation such as biocides, pesticides, cosmetics, fertilisers,  etc. Finally, the challenges caused by defined groups of chemicals such as endocrine disruptors or nanomaterials may also be addressed by additional measures.

Why is it important?

While being of natural origin, Industrial minerals qualify as substances. Consequently, all industrial minerals substances fall under the scope of the CLP regulation and are classified and labelled according to their physical, health and environmental hazards.

Like other chemical substances, industrial minerals must face obligations under REACH. Most industrial minerals are however exempted from REACH Registration obligations as they are “naturally occurring substances not chemically modified” (REACH Regulation, Annex V.7 on exemptions). For those industrial minerals falling under the scope REACH, IMA-Europe is managing REACH Consortia and providing support to its members for the completion and submission of registration dossiers.  

Where an industrial mineral is used in an application covered by specific legislation, compliance with the regulatory requirements must also be achieved accordingly. This is notably the case for the use of lime or borates in biocide applications or calcium carbonate, kieselguhr, quartz sand, talc, kaolin or hydrated lime as active substances in plant protection products.

Our views

Health and safety are core values of the Industrial Minerals Industry. We are committed to continuously improving our knowledge of industrial minerals to ensure that potential hazards are well identified and that the related risks are addressed by effective, proportionate, and inclusive risk management measures. In this line of thought, the Industrial Minerals Industry calls for future EU initiatives on Chemicals Policy to evolve towards a risk-based approach, instead of mainly focusing on the hazardous properties of a substance. In many cases, risk evaluations and the adoption of subsequent risk management measures will achieve the required health or environmental protection while providing better socio-economic perspectives than a complete ban or restriction on the use of the concerned chemicals in Europe.

To address chemicals policy in an effective and meaningful way, IMA-Europe adopts a science-based approach supported by facts and figures. This is achieved by building a toxicity and eco-toxicity database for all industrial minerals in the IMA-Europe portfolio and by directly and voluntarily contributing to research projects and initiatives from academia, industry groups, or (national) authorities in various scientific fields.

Finally, IMA-Europe highly values collaborations with other industry partners and constructive exchange with Authorities on Chemicals Policy. Our Association is thus an active member of the industry coalition for inorganics REACH Alliance participating in the Commission Expert Group of Competent Authorities for the REACH and CLP Regulations (CARACAL). IMA-Europe is also a direct member of different Commission Expert Groups, notably on CLP, nanomaterials, or endocrine disruptors. We are also an Accredited Stakeholder Organisation (ASO) with ECHA where we contribute as an observer to scientific and regulatory committees such as the ECHA Nanomaterial Expert Group, HelpNet and the Biocide Products Committee.

Our positions

Read IMA-Europe’s memo on the status of coated minerals under REACH-July 2028 (Editorial revision October 2021 here.

Read IMA-Europe’s position on calcined minerals-October 2015 (Editorial revision October 2021) here.

Read IMA-Europe’s position on fused minerals-July 2018 (Editorial revision October 2021) here.