Fall Forum of the Industrie-Gemeinschaft Aerosole e.V.

On November 21, 2019 in Frankfurt

Numerous representatives of the association’s member companies came to the the fall forum of the Industrie-Gemeinschaft Aerosole e.V. in Frankfurt to talk about current topics in the aerosol industry in Germany and learn about the association’s work in the last year, to exchange ideas, and to network. After greeting the participants, the Chair of the IGA, Volker Krampe, briefly explained the program, which was very well-organized and reflected current topics extremely well. Next, Matthias Ibel, Managing Director of the IGA, presented the report of the Chemical-Technical Committee about the current state of discussion of the following topics: 

  • Aerosol cans made of plastic
  • Draft for the adaptation of Annex II of the REACH regulation (safety data sheets)
  • Packaging law: Additions to the catalog of packaging requiring system participation
  • Speaker draft about the recycling management law
  • Packaging chain forum: Joint statement about “essential requirements” for packaging
  • Guidelines for the explosive raw materials regulation
  • Plastic aerosol packaging

Although on the level of the member states there is no more need to discuss safety requirements for plastic aerosol cans, according to Ibel, an adjustment of the aerosol guideline will unfortunately not be part of the EU Commission’s work in 2020. The reason for this is the Commission’s numerous questions about the recycling of plastic aerosol cans, which should be answered before publication of such an adjustment guideline. Therefore, intensive work is currently being done on this in an FEA working group, Ibel emphasized.

The FEA standard 647 “Plastic aerosol packaging,” which previously existed only in a draft version, should only be passed finally after the adaptation of the aerosol guideline has been published. However, in September 2019, the FEA agreed upon the passage and publication of the standard despite the yet-to-be-passed adaptation guideline. Another broad agreement about the standard and corrections to the German-language version should be taken into consideration here, said Ibel.

The schedule for passage of a current draft for the adaptation of Annex II of the REACH regulation (safety data sheets) has not been determined yet. 

Furthermore, Ibel reported about a supplement published in summer 2019 to the catalog of packaging requiring system participation by the Zentrale Stelle Verpackungsregister [Central Packaging Registration Office]. The only new aerosol product named here is mounting foam, which, due to its classification as a product containing hazardous materials, will be identified such that it does not require system participation. 

About the current speaker’s draft of the recycling management law, Ibel explained that it provides an expansion of product responsibility with regard to a “duty of care” for products sold. Accordingly, an authorization to make product-related regulations shall be provided in the law in order to prescribe guidelines to maintain the suitability for use of products and greater transparency with regard to the handling of goods that can no longer be sold. 

In a coordinated position paper about the enhancement of the basic requirements for packaging according to Annex II of the packaging waste guidelines signed in the “Packaging Chain Forum” of the FEA together with 42 additional associations, among other things a regulation is required according to which all packaging that is marketed in Europe should be designed for recycling by 2030. With this paper, the associations are supporting the corresponding strategy of the European Commission. Furthermore, it was emphasized that such a new regulation must consider the many and various packaging functions in order to achieve an appropriate compromise in each individual case between these functions and the environmental compatibility of packaging. 

Ibel then explained the essential contents of the regulation (EU) No. 2019/1148 about raw materials for explosive materials. Fortunately, the industry’s notes about the guideline for this regulation still being agreed upon have been considered to the extent that there is no more talk about the marking of the products falling under the regulation for the purpose of informing the supply chain. 

Mr. Ibel informed people that the 8th edition of the UN GHS has been published. In terms of the content, no changes were made for the classification and marking of aerosols. Only section 2.3 was rewritten by adding the new category “Chemicals under pressure.”

There was no progress on the CARACAL level for the consultations about the health and environmental classification of aerosols according to CLP. Currently, this topic is no longer on the agenda, said Ibel. 

Furthermore, Ibel explained the EU market monitoring regulation, which should create harmonized regulations within the EU. 

Finally, Ibel referred to a draft guideline on the topic of “dual quality,” according to which the varying composition of products marketed as identical in various European member states will count as misleading in the future. The draft underlying this planned re-regulation, that in particular member states some products presented as identical are offered in lower quality was not, however, confirmed by a study commissioned by the EU Commission in the summer. 

Michael Fürst then reported on the current consultations about the following FEA and CEN standards: Among other things, in the course of the systematic 5-year review the French association CFA proposed retracting the FEA standard 646 (03/2014) “Filled aerosol packs – Resistance to a top load force” since the methods stored in the standard no longer exist. 

Here too, the FEA standard 642 (03/2009) “Aerosol gaskets – Olfactive control test” was examined, said Fürst. Here, the FEA working group would propose the retraction of the standard since, according to the delegates represented there, it will no longer be applied. 

Volker Krampe, Chair of the IGA, presented the current safety and hazardous goods topics to the member companies.

Krampe said that several technical regulations are currently being reworked. For the IGA, TRGS 510 is of special interest, whose Annex 2 (storage in sales rooms) should clearly be canceled. He indicated that with the BGHW brochure “Spray cans and gas cartridges in sales rooms” (96/2014; BGI 646), however, there is already an industry regulation for aerosols in which the contents of Annex 2 of TRGS 510 are included. Reference can be made to this in the future, even if the TRGS 510 is changed accordingly. 

Krampe also reported that in the new hazardous material regulations that apply for two years starting in 2019, there are no changes to the section “Hazardous goods in limited quantities” important for the industry. 

Furthermore, Krampe reported that the increasing of internal pressure at 50°C was taken over for the use of compressed gases as propellants for European transport modes. Together with its American sister organization HCPA, the FEA is applying for the implementation in the UN model regulations, so that this regulation will be considered in all international regulations. 

Professor David Zaruk, author of the blog, gave an impressive talk entitled ”Whose facts are you using? Building trust in a suspicious world.” 

In addition, Mr. Stanislaus Koch, Association of the Chemical Industry, Department of Science, Technology, and the Environment, Product Safety Division, spoke in detail about current developments in recipe reporting according to Annex VIII of the CLP regulation. 

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