Important to regulate consumer products
SFT recommends
SFT upholds the proposal that the following substances need to be regulated in consumer products: Bisphenol A, the brominated flame retardant HBCDD, medium- chain chlorinated paraffins (MCCP), muskxylen, pentachlorophenol, triclosan, the perfluorinated compound PFOA and the heavy metals lead, cadmium and arsenic and their compounds.
The ten substances have been chosen on the basis of their harmful effects, the knowledgebase of their occurrence in consumer products and in the environment, scientific documentation and proposal comments. Having gone through the comments, we suggest some changes in limit values and extent of exceptions for the ten substances where it has been deemed possible to ensure necessary protection of health and environment.
Waiting for EU regulation of some of the substances
There are currently ongoing separate processes in the EU for the phthalate DEHP, organotin compounds and the brominated flame retardant TBBPA. We recommend waiting for the results of these processes before proposing national regulations. SFT suggests leaving muskketone and tensides out of the evaluation as updated information states that based on current consumption there is no risk associated with these substances.
Electronics and electrical appliances
Previously particular attention has been given to the consequences of the ban will have for trade of electrical and electronic appliances, such as mobile phones, flat screen TVs and computers.
SFTs suggestion for these products builds on international standards already followed by several large producers of EE-products. Consequently, there are already products on the market that fulfil the criteria, even though not all producers follow these standards and fulfil these demands today.
SFT considers the utilitarian value of banning EE-products containing substances harmful to health and environment far greater than the costs to society related to banning the products.
Consumers often lack knowledge related to health and environment problems related to use and waste management of products containing harmful substances. For this reason it is very important to regulate consumer products.
The whole population, including vulnerable groups such as children, are subject to exposure to consumer products, either directly or indirectly through the environment. Reducing the amount of hazardous substances in products is also important in order to reduce the amount of hazardous waste.
Will keep the best products
The new regulations will affect the kind of consumer products that can be traded in Norway. When formulating the regulation, SFT has emphasised international industry standards and the impact assessment shows that it is fully technically possible to fulfil the requirements.
-We wish to keep the best products on the market, while products with the most worrying effects for health and environment will no longer be legal, says the SFT Director General.
Products comprise a significant source of emissions of chemicals. The proposal will contribute to a significant limitation of potential emissions of these substances, even though it hasn’t been possible to quantify the emission reduction. The proposal is important in order to reach the ambitious targets for reduced emissions of hazardous substances, and is a part of the following up of report number 14 to the Storting (2006-2007) Working together towards a non-toxic environment and a safer future (government white paper).
A ban on production, import, export and trade
SFT recommends that the ban will include production, imports, exports and trade of consumer products that contain one or more of the ten substances when the substance content in the product exceeds or is equal to established limit values.
Delimitations to other product groups and other legislation
Furthermore, SFT recommends that the proposal for regulating certain hazardous substances in consumer products is established as a new chapter in the product regulation. The demarcation line towards other legislation will consequently be the same as for the product regulation. This means that the regulation will not include consumables, food packaging, fertiliser, tobacco and medicines. These products are regulated in other legislation.
Additionally we suggest that means of transport, rigidly mounted equipment for means of transport, tyres and similar fittings for means of transport are specifically exempted from the range of application of the regulation. The regulation will not cover substances and products that are already regulated through harmonised EU legislation (product regulation) either. This will for instance include certain substances in electrical and electronic products that are regulated through RoHS.
English version
SFT's letter to the Ministry of the Environment, including appendix 1, 4 and 5 will be translated and published here after August 18, 2008.