Description
ECPA Position Paper on the proposed Regulation 1107/2009 Annex III impurity limit in PPPs
The 0.01% limit for unintentional impurities contained in the draft Reg 1107/2009 Annex III proposal is a more problematic element of the text than currently seems to be generally recognised, and it needs to be reconsidered. The proposed limit is 10x lower than the comparable limit for impurities established and implemented through REACH and CLP Regulations, no justification for the approach has so far been provided, and it is expected to cause significant and unjustified implementation difficulties together with high compliance costs.