The ECHA suggestion to limit siloxanes D4, D5, and D6 under REACH has raised an alarm in industry. The European organization of silicone manufacturers (Centre Européen des Silicones: CES) represents the manufacturers of silicone polymers and fears a negative effect on the emission of carbon dioxide.
Siloxanes D4, D5, and D6 are already classified as substances of very high concern (SVHC). According to REACH (EU) 2018/35 that has been in effect since January 2018 for example, that’s why wash-off cosmetics that contain both siloxanes D4 and D5 in a concentration of 0.1% by weight may not be marketed after January 31, 2020. The current plans of the ECHA call for these thresholds soon to apply to other mixtures, such as leave-on cosmetics or the use of D5 in dry cleaning. The authors of the ECHA document regard the use of the substances in cosmetics as especially critical, given that about 18,000 tons of D4, D5, and D6 wind up in the environment every year. The authors claim that most of that amount comes from cosmetics.
Representatives of the CES argue on the opposite side. They are against a general concentration threshold because the siloxanes involved are also contained as contaminants in silicon polymers, an important raw material in the manufacture of insulating materials and medical products. They claim in their statement of February 1 that a restriction would not only affect manufacturers of silicon polymers, but also endanger high safety and sustainability standards for building materials, for example.
The authors of the ECHA dossier want to evaluate more information as part of a public consultation that begins in March to make a more accurate judgement of the current situation of polymers.
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