ARGE Response to proposed ECHA Guidelines
The European Chemical Agency (ECHA) has produced draft guidelines on the use of Nickel and Nickel compounds in a range of materials and products. Although voluntary, ARGE believes this is likely to impact on many of the products manufactured by its members.
The draft guidelines from the ECHA plan to restrict nickel and nickel compounds in articles ‘intended to come into direct and prolonged contact with the skin’ with ‘keys, key rings and key fobs’ being explicitly named. The guidelines will be introduced as voluntary actions but it is likely that these recommendations will gain more authority and have an increased impact on manufacturers in the future.
In response to the proposals and due to its likely impact across Europe, ARGE invited comment from all its members and has submitted a letter to the ECHA on behalf of all members. The letter can be downloaded from the members resource section on the ARGE website.
Originally brought to the attention of ARGE by the German Fachverband, in its comments to the ECHA, ARGE outlines the reasons it does not accept the inclusion of keys in the proposed guidelines. Covering both general and product specific considerations, ARGE identifies the following factors to be taken into consideration:
- Lack of socio-economic analysis – such research should be undertaken before any decisions regarding new and amendments to current restrictions are made.
- Disproportion of the nickel restriction – a reaction to nickel cannot cause an anaphylactic shock and is less harmful than the reaction caused by other non-restricted items in, for example, food and cosmetics.
- Importance of nickel in keys – this is required to ensure a high quality and durable product, for which no alternative is currently available
- Skin contact with keys – it is highly unlikely that a person would have what is deemed ‘prolonged skin contact’ with keys
- Disproportion of a restriction of keys – an inclusion of keys into the scope of the guideline will lead to a disproportionate (to the degree of risk) uncertainty for retailers and end users.
ARGE awaits feedback from the ECHA on its comments and would encourage all members to understand and engage with this debate.