Product Policy Archives

USCIB to Participate in Global Chemicals Management Conference

Published on September 12, 2012

africaAgainst the backdrop of growing international attention to the use of chemicals throughout the production and consumption chain, Helen Medina, USCIB’s director of life sciences and product policy, will attend the Third International Conference on Chemicals Management (ICCM3), September 17-21 in Nairobi, Kenya.

In 2006, ICCM adopted the Strategic Approach to International Chemicals Management (SAICM) as a policy framework to foster the sound management of chemicals. SAICM was developed by a multi-stakeholder and multi-sectoral preparatory committee, and supports the achievement of the goal – agreed at the 2002 Johannesburg World Summit on Sustainable Development – of ensuring that, by the year 2020, chemicals are produced and used in ways that minimize significant adverse impacts on the environment and human health.

ICCM3 will mark a major milestone in the implementation of the Strategic Approach. The conference will evaluate implementation, address emerging policy issues including the chemicals in products project, consider new activities for addition to its global plan of action, evaluate the financing of SAICM and take strategic decisions for the future.

SAICM is a voluntary policy framework, implemented in a multi-stakeholder process, and sets as one of its main objectives that information and knowledge about chemicals contained in products “is available, accessible, user friendly, adequate and appropriate to the needs of all stakeholders.” As a step towards fulfilling this objective, the second session of the governing body of SAICM in 2009 (ICCM2), recognized chemicals in products as an emerging policy issue, and adopted a resolution which invited UNEP to lead a Chemicals in Products (CiP) project.

Since ICCM2, the UN Environment Program, the lead agency for this topic, has focused its work on understanding the availability of information on CiP. It commissioned in-depth studies in specific sectors (building materials, toys, electronics, textiles) on this topic and a workshop to make suggestions on how to move the project forward. The major recommendation from the workshop and the preparatory meeting for ICCM3 was to develop a voluntary framework to facilitate the flow of information on CiP.

USCIB is attending ICCM3 to ensure that business interests are considered as the recommendation for the next steps for the CiP project is finalized. In essence, USCIB believes that the CiP project can be a valuable opportunity to exchange experiences and best practices to achieve the goal of sound management of chemicals by 2020. Significant progress has been made in some industry sectors, and via internationally agreed standards processes, to identify priority information and key points along the life cycle where information should be communicated.

In its comments to ICCM3, USCIB recommends that the CiP project build capacity for the implementation of existing systems that facilitate the exchange of relevant information on chemicals in products, including through training tools and workshops. USCIB said that while industry appreciates the importance of exchanging appropriate and relevant information related to chemicals in products, it is crucial that confidential business information be protected.

Staff contact: Helen Medina

USCIB comments for ICCM3

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APEC Regulators Forum Looks at Challenges Faced by Manufacturers

Published on April 13, 2012
APEC Regulators Forum Looks at Challenges Faced by Manufacturers
APEC Regulators Forum Looks at Challenges Faced by Manufacturers

USCIB members took part in a panel discussion at the APEC (Asia-Pacific Economic Cooperation) Regulators Forum on March 30 in Singapore, drawing attention to some of the challenges manufacturers face in many countries with respect to chemicals regulation, which is having an increasing impact on downstream users of chemicals.

For the past several years the APEC Chemical Dialogue has discussed how best to contribute to APEC’s overarching goals of trade liberalization and business facilitation throughout the Asia-Pacific region.

Moderating the discussion and speaking on behalf of USCIB was Sophia Danenberg (Boeing)¸ who said the panel was intended to gauge the interest of APEC economies on this topic and elicit thoughts for next steps, if any, for region-wide action.

The discussion was productive, with a consensus among participants that regulating chemicals in articles is a complicated matter, and that further discussion on the topic is needed. It revolved around how various industries are dealing with the need to communicate substances in articles along the supply chain.

Timo Unger (Hyundai) described how complex supply chain communication can be for the automotive industry. A single vehicle, he said, can contain hundreds of thousands of articles, most of which are pre-manufactured, which makes understanding what substances they contain and communicating that information throughout the supply chain a major challenge.  As a result, auto companies have created an international database for original equipment manufacturers to manage environmentally relevant aspects of the different parts used in vehicles.

Andrea Fava (Intel), representing the Information Technology Industry Council, shared the electronics industry’s experiences and approach to materials declaration. She said the industry has its own database on material declaration, which is meant to harmonize requirements across the supply chain and improve economic efficiencies. Komei Kimura (Japanese Environmental Management Association for Industry) noted a joint article management consortium established in 2006 by 17 member companies across various industries to develop a system for exchanging information on chemicals in articles across various supply chains.

Matthew Gredley, from the Australian health department, gave a regulator’s perspective on the challenges faced in obtaining information about chemicals in articles.  He specifically noted the Australian government’s assessment of diethylhexyl phthalate, a plasticizer used in industrial and consumer products, and the challenges that Australia had in obtaining information on the level of that chemical in articles.

It is clear that both industry and APEC member economies share the goal of the sound management of chemicals throughout their life-cycles. There is a need to share and have access to relevant information regarding the chemicals in articles for a variety of reasons, including to allow economies to assess and mitigate risks to human health and the environment, enable industry to demonstrate compliance to regulatory requirements and inform environmentally conscious design.

Furthermore, while information sharing is crucial, a balanced approach is required that recognizes and respects the important concept of intellectual property and protection of confidential information, as well as consumers need to know.

Staff contact: Helen Medina

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EU-Style Chemicals Regulation Being Pushed in Various Forums

Published on March 12, 2012

4269_image002On March 7 in Baltimore, Helen Medina, USCIB’s director of life sciences and product policy, took part in the annual GlobalChem conference, speaking on a panel on “Regulating Chemicals in Products/Articles.” For over 20 years, GlobalChem has provided a forum for discussion of the U.S. Toxic Substances Control Act, equivalent international regulations, and emerging issues and trends in the product stewardship arena.

The panel focused on the increasing pressure for U.S. manufacturers, importers and exporters to meet applicable governmental reporting requirements (including the European Union’s REACH effort), as well as content restrictions such as state chemical-specific laws in the U.S. and the EU’s Restriction of Hazardous Substances (RoHS II) initiative, without knowing fully what chemicals their suppliers have used in making the products they purchase and those used in making or selling their own products. In addition to Medina, the other panelists were Mike Irwin (Procter & Gamble), Andrea Fava (Intel) and Ernie Rosenberg (American Cleaning Institute).

Panelists reviewed increased government reporting requirements and content restrictions, as well as compliance through supply-chain management, and identified the challenges and solutions for companies selling products that incorporate chemicals or components supplied by others. USCIB’s Medina spoke about how the regulation and information-sharing about chemicals in articles are unfolding in the international arena. She described the specific obligations EU REACH sets out for manufacturers of articles, and she called attention to South Korea’s efforts to introduce REACH-style.

Medina also described how the UN efforts, including the Strategic Approach to International Chemicals Management (SAICM) initiative, are addressing chemicals in products and providing a platform for some to call for increased sharing of environmental information. She warned of the spread of REACH-like approaches outside the EU, the use of SAICM as a platform to facilitate this, and the potential “perfect storm” brewing in various multilateral forums – from June’s Rio+20 conference to the International Conference on Chemicals and Chemicals Management – to validate the inclusion of REACH-style measures in an international treaty built on the SAICM initiative. Medina said the time is now for business to engage with governments in the run-up to Rio+20 and in SAICM discussions in order to shape desired outcomes.

Staff contact: Helen Medina

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USCIB Keeps Tabs on UN Discussions of Chemicals in Products

Published on November 30, 2011

4208_image002Helen Medina, USCIB’s director of life sciences and product policy, recently attended the Open-Ended Working Group (OEWG) meeting of the UN’s International Conference on Chemicals Management (ICCM) which was held November 15-18 in Belgrade.

In 2006, ICCM adopted the Strategic Approach to International Chemicals Management (SAICM) as a policy framework to foster the sound management of chemicals.  SAICM was developed by a multi-stakeholder and multi-sectoral preparatory committee, and supports the achievement of the goal – agreed at the 2002 Johannesburg World Summit on Sustainable Development – of ensuring that, by the year 2020, chemicals are produced and used in ways that minimize significant adverse impacts on the environment and human health.

The functions of the OEWG are to consider the implementation, development and enhancement of the Strategic Approach to International Chemicals, and to make recommendations for ICCM3, which will be held in September 2012 in Nairobi.

The overarching issue that impacted the discussions at the OEWG surrounded the financing and technical resources for implementing SAICM goals. This included the financing of the Quick Start Program and of SAICM itself. As such, many delegates felt that unless financing and technical issues were resolved, there was little point in discussing other issues for possible inclusion on the provisional agenda of ICCM3.

To deal with the issue of long-term and short-term finance issues, the president of the meeting created a “Group of the Friends of the President” and a “Committee of the Whole (COW)” to prepare draft decisions or resolutions for possible adoption by ICCM3. Although there were several issues of interest that USCIB followed during the meeting, it was the Chemical in Products project which has generated the most interest among USCIB’s members.

SAICM is a voluntary policy framework, implemented in a multi-stakeholder process, and sets as one of its main objectives that information and knowledge about chemicals contained in products “is available, accessible, user friendly, adequate and appropriate to the needs of all stakeholders.” As a step towards fulfilling this objective, the second session of the governing body of SAICM, the International Conference  for Chemicals Management (ICCM2), in May 2009 recognized chemicals in products as an emerging policy issue, and adopted a resolution which invited UNEP to lead a Chemicals in Products (CiP) project.

Since ICCM2, the UN Environment Program, the lead agency for this topic, has been focusing its work on understanding the availability of information on CiP. There were in-depth studies in specific sectors on this topic and a workshop was held to make suggestions on how to move this project forward. The major recommendation from the workshop was to develop a voluntary framework to facilitate the flow of information on CiP.

For a more detailed report of the meeting please refer to the Draft Report of the Work of the Open-ended Working Group of the International Conference on Chemicals Management at its First meeting, the Addendum to the Draft Report of the OEWG, and the Draft Decisions Submitted by the Committee of the Whole.

Staff contact: Helen Medina

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Countries Decline to Ramp Up Disclosure of Product Information

Published on July 8, 2011
USCIB’s Helen Medina at the conference in Chisinau, Moldova
USCIB’s Helen Medina at the conference in Chisinau, Moldova

Timely work by USCIB and other business groups around an intergovernmental conference paid off when parties to the Aarhus Convention rebuffed efforts to widen possible public environmental disclosure rules to include proprietary product information.

The scene was the fourth meeting of parties to the convention, which took place June 27 to July 1 in the Moldovan capital Chisinau. Attending on behalf of business and industry were Helen Medina, USCIB’s director of life sciences and product policy, attended the meeting in Moldova and was joined by Alessandra Salamini (Monsanto), Michelle Orfei (Croplife International) and Robbie Schreiber (European Crop Protection Association).

Formally known as the UN Economic Commission for Europe Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters, and named after the Danish city where it was signed in 1998, the Aarhus Convention links environmental protection and human rights, laying our procedures for public access to information, participation and redress in local, national and cross-border environmental matters. Some 40 European and other countries are party to the convention.

“The Aarhus Convention is not just an environmental agreement,” noted Ms. Medina. “It is also about government accountability, transparency and responsiveness. It grants the rights to the public, and it imposes obligations on countries and public authorities regarding access to information, public participation and access to justice.”

Industry representatives were interested in how the convention work program for 2012-2014 would be implemented, especially the work plan for a task force aimed at widening the range of information – including privately held product information – made available to the public. In the end, parties to the convention opted to delete the reference to product information.

“This was a win for us, brought about largely because, prior to the conference, industry did a lot of work on educating the European Union about the slippery slope of giving the public have direct access to product information from the private sector,” Ms. Medina said. “In the end, it was the EU that changed the language.”

USCIB and other industry groups will continue to monitor future discussions to see how this language in the work program translates into practice.

Business also sought to learn how Aarhus Convention principles are being promoted at the global level and in other international environmental discussions. Stakeholders at the Chisinau meeting issued a declaration, “Rio Plus Aarhus – 20 Years On,” which highlights the importance of promoting Aarhus principles of openness, transparency, wide participation and accountability in international environmental decision-making in preparation for the Rio+ 20 Conference in 2012. In this context, the business delegation delivered an intervention which highlighted the need of wide stakeholder engagement in matters relating to sustainable development.

On the last day of the meeting, USCIB’s Ms. Medina delivered a business statement highlighting the positive role companies can play in providing practical solutions to complex global environmental challenges. She stressed the need for improved governance and policymaking, as well as a multi-stakeholder approach, in tackling such environmental challenges as climate change, energy security, waste management, water scarcity and population growth.

 

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USCIB Urges Changes to Proposed Korean Chemicals Regulation

Published on May 11, 2011

korea_flagThe Korean environment ministry recently proposed far-reaching regulations, modeled largely on European Union law, on the use of chemicals.  In response, USCIB engaged its members and submitted comments, supporting other submissions by business and industry groups, including the American Chemistry Council.

The regulations would amend Korea’s toxic chemicals control act and introduce many elements similar to those found in the EU’s REACH law on chemicals, including priority chemicals, chemicals for authorization, chemicals for restriction, pre-registration of priority chemicals and communication of information throughout the supply chain.

USCIB urged that manufactured products or articles be excluded from all the regulation’s provisions, and that exclusions for such articles not require a confirmation that they are exempt.  “A requirement that manufacturers or importers submit an application for confirmation of an exemption would be inefficient and wasteful,” the USCIB letter stated.

Under a World Trade Organization agreement on technical barriers to trade, Korea must notify the organization when it prepares or adopts a new technical regulation or standard, and other WTO member nations may comment on such measures.

Staff contact: Helen Medina

USCIB Letter to Korean Environment Minister

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Global Challenges Face Consumer Products Manufacturers

Published on December 15, 2010

Helen Medina, USCIB’s director of life sciences and product policy, participated in the Consumer Specialty Products Association 7th Annual International Affairs Conference — Global Challenges, Trends and Outlook, December 4 and 5 in Fort Lauderdale, Florida.

The CSPA program covered three areas: a downstream user’s perspective on compliance with the European Union’s REACH program to regulate use of chemicals; new regional product stewardship and trade developments impacting market access in Latin America; and developments at the global level.

The later topic area covered multilateral discussions of the Globally Harmonized System of Classification and Labeling of Chemicals, environmental and product sustainability, and consumer product safety.  It included an in-depth panel discussion featuring Ms. Medina on global product strategy and product stewardship in the consumer products industry, and throughout the production chain.

Ms. Medina’s presentation demonstrated how international high-level discussions can impact chemical companies.  Chemicals – and more specifically chemicals in products, and how they can impact human health and the environment – are high on the international agenda, she said.  Although international negotiations may take years to conclude, eventually the outcomes of the talks make their way into national law and regulation.

Consumers, governments and NGOs are increasingly vigilant in requesting that companies disclose information concerning formulations, ingredients and chemicals used in products, Ms. Medina said.  She cited the UN’s SAICM (Strategic Approach to International Chemicals Management) as just one of many ongoing discussions related to chemicals and emphasized the importance of becoming involved in the UN’s preparations for the Rio+ 20 conference, which takes place in 2012 and will mark the 20th anniversary of the watershed 1992 Rio Earth Summit.

The main themes of Rio + 20, said Ms. Medina, are the green economy and governance for sustainable development, both of which will undoubtedly touch upon how chemicals are managed. These discussions are extremely important because the conference’s expected final document will most likely be a political one, while possible outcomes range from potential treaty negotiating mandates to institutional changes to promote greater scrutiny of chemicals worldwide.  Additional expectations for business and other non-government actors are a given, she said.

The panel was moderated by John Phillips of Cardno ENTRIX.  Other panelists included Greg Skelton of the American Chemistry Council and Patricia Barone of Unilever.

Staff contact: Helen Medina

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UN Talks on Global Chemicals Database May Impact Broad Swaths of Industry

Published on March 3, 2009

UNEPKimberly McLaughlin, USCIB’s director of product policy, nanotechnology, China, EU, and APEC affairs, recently represented American business in Geneva at a UN Environment Program informal workshop on a proposed global database of chemicals used in articles and products worldwide.  At this gathering of over 100 government, academic and NGO participants, Ms. McLaughlin underscored U.S. business concerns that confidential business information be protected and provided insight into managing the scope of this proposed project, highlighting the diversity and complexity of information across business sectors.

The scope of a chemicals database – which was first proposed last year by the EU, Japan and the Intergovernmental Forum on Chemical Safety as an emerging issue to be addressed in the UN’s Strategic Approach to International Chemicals Management (SAICM) process – will be negotiated at the upcoming second session of the International Conference on Chemicals Management, in Geneva May 11 to 15.  USCIB will lead a business delegation, encompassing particularly those downstream chemical users who can be greatly affected by discussions of global chemicals policy.

Sweden has taken the lead in the development of the issue, co-chairing the informal workshop in Geneva, as well as providing a representative to act as the facilitator in the preparation of conference documents to which USCIB has recently submitted comments (available on our product policy resource page, under “recent accomplishments”).  This round of comments on the draft conference documents is expected to close by March 9.

At the Geneva workshop, many NGOs and governments raised the issue of exposure of chemicals from articles and products that are found in computers, textiles, toys and jewelry as well as the problem with the recovery of chemicals from products in waste management.  There were calls for an international harmonized database of chemicals in articles and products throughout the supply chain and extended producer responsibility.  Several participants at the workshop called for an international binding instrument that would lead to a compulsory database of chemicals information in articles all through the supply chain with the hope towards substitution and alternatives.  USCIB is concerned that, if these calls and proposals were to be implemented, there would be a significant impact on companies across numerous industries, regardless of size and nationality.

USCIB is seeking to raise awareness of this issue among its members and global business partners.  Many companies and industries already invest heavily in infrastructure to provide information about the use and exposure of potentially hazardous substances in their products.  These companies and industries also invest significant time and effort in establishing, maintaining and improving product end-of-life recycling and management programs.  USCIB believes it would be valuable to use these experiences as a basis for consideration of additional work, and provide a strong business voice to these ongoing negotiations and future mandate of this project.

Those wishing to learn more should contact Kimberly McLaughlin at kmclaughlin@uscib.org.  The next USCIB Product Policy Working Group meeting is scheduled for March 9 in Washington, D.C., where members will discuss next steps and USCIB engagement in this process.  Members should contact Justine Bareford at jbareford@uscib.org to register.

Staff contact: Helen Medina

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SAICM negotiations website

U.S. Business Urges Revision of European Chemicals Guidelines

Published on September 13, 2006
Proposed EU chemicals legislation could impact downstream users as well as importers.
Proposed EU chemicals legislation could impact downstream users as well as importers.

New York, N.Y., September 13, 2006 – The United States Council for International Business, which represents America’s top global companies, has voiced concern to European Union authorities over proposed implementation guidelines for EU legislation, known as REACH, to regulate over 30,000 chemicals and products made from them.

REACH, which stands for “registration, evaluation, and authorization of chemicals,” is slated to undergo its second reading in the European parliament this fall. As currently drafted, the proposed legislation would affect downstream users and importers as well as chemical manufacturers.

USCIB submitted comments on a draft REACH implementation project or (known as RIP 3.8) that sets out guidance for manufacturers in the implementation of the draft chemicals legislation. It said its comments aimed to help contribute to the workability of rules laying out the obligations under REACH for industries that use chemicals in the manufacture of their products.

“The workability and proportionality of REACH has been raised as a top priority by both the European Commission and Council,” said Andrea Fava, USCIB’s manager of environmental affairs. “However, we are concerned that these guidelines are neither workable nor proportionate.”

USCIB recommended the revision of the proposed guidelines, saying its members are concerned about the workability of the draft from both the compliance and enforcement perspectives. USCIB has also expressed concern that the guidelines go beyond the scope of the draft chemicals legislation.

“We urge that further input be considered and that the guidance for articles be revised to ensure it is consistent with the intent of the draft REACH legislation,” said the USCIB statement.

In 2003 and 2004, USCIB submitted comments to the European Commission on the economic and environmental impact of the REACH proposal. Since then the EU has undertaken an extensive revision of the proposed legislation and is now pushing to finalize REACH in the near future.

USCIB promotes an open system of global commerce in which business can flourish and contribute to economic growth, human welfare and protection of the environment. Its membership includes some 300 leading U.S. companies, professional services firms and associations whose combined annual revenues exceed $3 trillion. As American affiliate of the leading international business and employers organizations, USCIB provides business views to policy makers and regulatory authorities worldwide and works to facilitate international trade.

Contact:
Helen Medina
(212) 703-5047 or hmedina@uscib.org

USCIB comments on on REACH Implementation Project 3.8

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