Comments on ECHA’s Draft 9th Recommendation for 2-ethoxyethanol (EC number: 203-804-1) and references to responses

The present document compiles the comments received during the public consultation on the draft 9th recommendation for inclusion of substances in Annex XIV of REACH for 2-ethoxyethanol (EC number: 203-804-1). The public consultation took place between 5 September 2018 and 5 December 2018.

For each of the comments there is also a reference to specific section(s) of a document containing the responses to comments (“Response document”, available at https://echa.europa.eu/documents/10162/13640/9th_recom_respdoc_methoxy_ethoxyethanol_en.pdf). The responses in the Response document are arranged by thematic block and level of information (see more detailed explanations at the beginning of that document).

Public version

Content
	
I - General comments on the recommendation to include the substance in Annex XIV
II - Transitional arrangements. Comments on the proposed dates
III - Comments on uses that should be exempted from authorisation, including reasons for that

I - General comments on the recommendation to include the substance in Annex XIV
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3327
2018/12/05	ADS Group Limited,
Industry or trade association,
United Kingdom	The substance 2-Ethoxyethanol (also known as Ethylene glycol ethyl ether (EGEE) and Ethyl Cellosolve) CAS 110-80-5 was identified as an SVHC and added to the REACH Candidate List on 15th Dec 2010 due to its Toxic for reproduction (Article 57C) properties and is currently in the 9th recommendation to be added to Annex XIV.
2-Ethoxyethanol is an organic solvent widely used in commercial and industrial applications such as in the semiconductor industry. Due to its ability to dissolve chemically diverse compounds such as oils, resins, grease, waxes, nitrocellulose and lacquers it is used in products such as varnish removers and degreasing solutions. It is also used as a solvent in paints and varnishes, printing inks, lacquers, wood stains and epoxies. It is a constituent of some adhesives and corrosion resisting bonding primers used widely it aerospace applications.
	A.1.1.5. New information and next steps towards the final recommendation

A.1.5.5. Availability of suitable alternatives	
				
3350
2018/12/05	ChemSec,
International NGO,
Sweden	ChemSec supports the prioritisation of 2-ethoxyethanol for inclusion in Annex XIV.	Thank you for your opinion.	
				
3351
2018/12/05	ChemSec,
International NGO,
Sweden	ChemSec supports the prioritisation of 2-ethoxyethanol for inclusion in Annex XIV.	Thank you for your opinion.	
				
3363
2018/12/05	CHEM Trust,
National NGO,
United Kingdom	CHEM Trust strongly supports the prioritisation of 2-ethoxyethanol for inclusion in Annex XIV.	Thank you for your opinion.	
				
3366
2018/12/05	Norway,
Member State	The Norwegian CA supports the prioritisation of 2-ethoxyethanol for inclusion in Annex XIV.
In general, the Norwegian CA supports grouping of substances of very high concern to avoid substitution with substances with similar properties within the same use categories.
	A.1.4.1. Relevant further considerations

Thank you for your opinion.	
				
3407
2018/12/05	AeroSpace and Defence Industries Association of Europe (ASD),
Industry or trade association,
Belgium		A.2.04. Document attached to comment relates to different substance	
		Attachment: 3407_ASD input_on_trilead dioxide phosphonate.pdf

II - Transitional arrangements. Comments on the proposed dates
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3327
2018/12/05	ADS Group Limited,
Industry or trade association,
United Kingdom	As with any product used in the aerospace industry the time to fully qualify and industrialise an alternative, if any identified is a very lengthy process. For potentially safety critical aerospace uses such as adhesives and in corrosion resistant bonding primers the qualification time will be even longer.	B.1.2.2. Lack of alternatives, socio-economic aspects	
				
3398
2018/12/05	Aerospace Industries Association (AIA),
Industry or trade association,
United States	The aerospace sector relies on surveys and encourages affected downstream users to collaborate in authorisation consortia (by joining or contributing) and voluntarily provide relevant data to third party consultants that aggregate the available data.  In the short 18 to 24 month timeframe after substance listing on Annex XIV and the Last Application Date, there is not always sufficient time to encourage enough supply chain actors to develop an accurate and comprehensive application.	B.1.1.3. ECHA's proposal for latest application dates

B.1.2.1. Extensive time needed in the supply chain to get organised for preparing application (e.g. due to high number of users)	

III - Comments on uses that should be exempted from authorisation, including reasons for that
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3327
2018/12/05	ADS Group Limited,
Industry or trade association,
United Kingdom	See above.	C.1.3. Aspects not justifying an exemption from authorisation