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The suggested restriction for substances which are carcinogenic, mutagenic, toxic to reproduction, skin sensitising, skin irritant, corrosive, eye damaging and irritant applies only to substances in Part 3 of Annex VI to the CLP Regulation, i.e. only to substances which have a harmonised classification. However, in many cases a harmonised classification is missing but industry has self-classified these substances as falling in the respective hazard classes. Hence, these restrictions should not only apply substances with harmonised classifications but also where 50% or more of the notifiers have self-classified the substances indicating these hazard classes (i.e. where a majority of the notifiers agrees on the classification).
ANEC appreciates the ban of carcinogenic or mutagenic substances cat. 1A, 1B and 2 but considers that a practical enforcement limit should be introduced and should be e.g. 10 ppm (0,001%) for cat. 1A, 1B and 100 ppm (0,01 %) for cat. 2.
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