Regulatory Update REACH Annex XIV

This information is an update on a recent decisions by the European Union regarding n-propyl bromide (nPB ), the base material for EnSolv®.

Substances in Annex XIV of REACH
Substances in Annex XIV of REACH have to get authorisation to be used by industry. Without authorisation the use of the substance will eventually be banned in the UK* and EU. The timescale for authorisations is as follows:

1. Applications for Authorisation must be received by the 4 January 2019 to insure uninterrupted use.
2. Without Authorisation the substance will be banned after 4 July 2020 (so called “Sunset Date”)

However before the sunset date and irrespective of any application for authorisation, the substance can be used without restriction. Enviro Tech are committed to the continuing safe use of n- Propyl Bromide as a vapour degreasing solvent and have disputed the classification through the courts. We are as committed as ever to support our very stable proprietary stabilised formulation. This explains the next steps that we will take to ensure the continued use of EnSolv®.

The Lead Registrant for the substance n Propyl Bromide is ICL Industrial Products who manufacture the base chemical. They are totally committed to support n-PB as a vapour degreasing solvent to continue to provide users with all the benefits this product offers. On September 13, 2017, ICL filed a lawsuit, ICL-IP Terneuzen, BV and ICL Euprope Cooperatief UA v European Commission, Case T-610/17, against the European Commission to annual the Commission Regulation (EU)2017//999 of June 13, 2017 amending Annex XIV to Regulations (EC) No. 1907 / 2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH (O) 2017, 150. p. 7) as far as it includes nPB on Annex XIV of the REACH Regulation.

A company of consultants have been retained to coordinate the authorisation of nPB in vapour degreasing processes. Our EnSolv® users are invited to provide details of their current process to be included in this program

EnviroTech Europe is confident that we will be given authorisation for certain defined vapour degreasing processes. Once established, this generic authorisation will set out specifications for the equipment and processes that need to be in place to enable end users to continue using EnSolv® under licence for a further period of time (probably up to 12 years) before renewal.

EnSolv® can continue to be used beyond the Sunset Date even if the decision to authorise has not yet been made.

• There are no restrictions on buying or using EnSolv® until 4th July 2020 at the earliest
• Alternatives have either a much higher boiling point (Perc) or a much lower boiling point (DCM, HFE, HFC, HFO) and therefore are far from optimum for vapour degreasing
• Alternatives Perc and DCM are Cat 2 Carcinogens
• Alternatives based on Fluorinated chemistry are more expensive, have lower solvent power and are actually based on trans 1,2 Dichloroethylene a flammable solvent

*For the UK, at this moment in time it is unclear what effect Brexit will have on REACH regulations. It is by no means certain that it will all be cut and pasted into UK law under the Repeal Bill. However if it is we have a submission for authorisations underway for it to continue to be used.