Published name
Which chemical or chemicals would you like to provide feedback on?
Have you read the proposed standard or standards for the chemical or chemicals selected?
Do you support the proposed standard or standards?
Would you like to provide further comment on these proposed standard or standards?
Do you or your organisation use Hexachlorobenzene?
Do you or your organisation use Hexachlorobenzene for any of the following purposes?
Please specify what you use the chemical for?
We do not intentionally use HCB. However, it may be generated as an unintended byproduct or impurity during the production process.
Are you aware of any substitutes for Hexachlorobenzene that are available for medical, veterinary, defence, national security, public safety, industrial safety, economic or environmental purposes?
If Hexachlorobenzene was/were no longer available, what impact would it have on your business?
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Does the proposed standard for Hexachlorobenzene manage the risk of the chemical being released into the environment?
Do the activities required for a business to meet the proposed standards for Hexachlorobenzene impose an unreasonable burden on business?
Please upload your document.
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ETAD Statement on HCB Limits Proposed by the Australian Government
ETAD also has serious concerns regarding the proposed limit of 5 mg/kg for Hexachlorobenzene (HCB) in organic pigments, which, like PCBs, can occur as an unintentional trace contaminant during pigment production. HCB is a byproduct that arises from the same chlorination processes used in the production of certain organic pigments, particularly those valued for their stability and vibrant colours. In the past, manufacturers have made significant efforts to optimize their processes to meet these stringent limits. However, due to the inherent presence of chlorine in its chemical structure and natural batch-to-batch variations that lead to the unintentional generation of impurities, it is not possible to achieve the proposed thresholds.
While reducing HCB content in pigments is an important environmental goal, the proposed limit is too restrictive and poses significant challenges to pigment manufacturers.
Impact of Proposed HCB Limit on Pigment Market and Supply Chains
Meeting the 5 mg/kg limit is technically unfeasible and could lead to severe market disruptions, especially for industries that rely on pigments with specific properties. Chlorinated organic pigments are widely used across industries such as paints, inks, plastics, textiles, and electronics. The availability of these essential pigments would be greatly impacted if the proposed HCB limit were enforced, resulting in disruptions across various value chains. Sourcing alternative pigments that meet the necessary technical and performance standards will be difficult and, in many cases, impossible without compromising quality and functionality.
Moreover, the global supply chain would face severe disruptions under the proposed
HCB limit. Pigments produced in markets without stringent HCB restrictions, such as
Asia, would no longer be eligible for import into Australia. Additionally, while the import of pigments with higher levels of HCB would be restricted, finished products containing those same pigments could still be able to be imported into Australia due to dilution effect, undermining the effectiveness of the regulation enforcement and allowing HCB to re-enter the market indirectly.
ETAD’s Recommendation
ETAD recommends that the Australian Government set a more feasible limit of 10 mg/kg for HCB, aligning with well-established international regulations. This limit is already in place under various legislatives, including the European Union’s Regulation (EU) 2022/2291 for persistent organic pollutants (POPs), the United States' Toxic Substances Control Act (TSCA) and Canada’s Environmental Protection Act (CEPA). These limits effectively protect the environment while acknowledging the technical realities of pigment production. In addition, a transition period of three years is essential to allow manufacturers to adapt to the new regulation for the most challenging colour indexes without causing sudden supply shortages or market disruptions.
Conclusion
ETAD acknowledges the importance of restricting HCB in pigments to protect the environment. However, the proposed limit of 5 mg/kg is unfeasible from both technical
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and economic perspectives and would severely disrupt the supply chain for essential pigments. ETAD recommends setting a more feasible limit of 10 mg/kg for HCB, aligning with global regulations, to ensure continued market stability. A transition period of at least three years would allow industries sufficient time to adapt to the new regulations.
With realistic limits aligned to international benchmarks, Australia can meet its environmental objectives without compromising local industry and ensuring access to key pigments. ETAD remains committed to collaborating with the Government on a solution that balances environmental responsibility with industry needs.
Is the chemical clearly identified in the proposed standard?
Would you like to provide any other information on this proposed standard for Hexachlorobenzene?
Do you or your organisation use Polychlorinated biphenyls?
Are you aware of any substitutes for Polychlorinated biphenyls that are available for medical, veterinary, defence, national security, public safety, industrial safety, economic or environmental purposes?
If Polychlorinated biphenyls was/were no longer available, what impact would it have on your business?
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Does the proposed standard for Polychlorinated biphenyls manage the risk of the chemical being released into the environment?
Do the activities required for a business to meet the proposed standards for Polychlorinated biphenyls impose an unreasonable burden on business?
Is the chemical clearly identified in the proposed standard?
Would you like to provide any other information on this proposed standard for Polychlorinated biphenyls?
You can upload a document to provide additional feedback on the proposed standard on this page.
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ETAD Statement on PCBs Limits Proposed by the Australian Government
The Ecological and Toxicological Association of Dyes and Organic Pigments
Manufacturers (ETAD) is a global association committed to the safety and continuous improvement of colourants. Representing many leading companies in the sector, ETAD plays a critical role in advancing safe manufacturing practices and promoting sustainability in the use of dyes and organic pigments.
ETAD wishes to express its concerns regarding the Australian Government's proposed limits on Polychlorinated Biphenyls (PCBs) in organic pigments, which establish an unreasonably low threshold of 2 mg/kg.
While ETAD shares the goal of reducing harmful substances in the environment, this proposal presents significant technical and practical challenges that could severely impact the pigment industry and the downstream users.
PCBs are often present as unintentional trace contaminants (UTCs) in organic pigments, particularly in chlorinated pigments, due to the chemical processes involved in their manufacture. These pigments are essential in numerous industries such as paints, inks, plastics, and textiles, and are valued for their superior fastness properties and the unique shades they provide. However, completely eliminating PCBs contamination at levels as low as 2 mg/kg is technically unfeasible, despite the fact that the production process effectively removes most PCBs and ensures their safe incineration.
Efforts by Industry to Reduce PCBs in Organic Pigments
Historically, PCBs were often unintentionally generated as by-products during pigment production processes. In the past decades, the pigment industry has made every effort to significantly reduce PCBs contamination, and considerable improvements in manufacturing practices over time have significantly reduced PCBs levels in pigments.
While these efforts have greatly reduced contamination, the complete elimination of
PCBs traces remains technically unachievable, and they can only be minimized.
ETAD companies have also carried out collaborative actions to tackle PCBs issues specifically:
- Development of ETAD Method 229
ETAD has led the way in creating robust testing methods under stringent conditions.
Unlike existing methods that focus on targeted congeners, ETAD Method 229,
developed in 2011, measures the total content of all PCBs congeners in organic
pigments, ensuring safer, more environmentally friendly products. It was adopted as
an ISO method in 2019, solidifying its status as a globally recognized standard
- PCBs Limit in ETAD's Guidance Document (Code of Ethics)
As part of ETAD’s commitment to Responsible Care, a limit for PCBs content was
integrated into our Guidance Document in 2015, reflecting our proactive approach to
ensuring product safety.
- Inclusion of Mono- and Di-Chlorinated PCBs in Monitoring
ETAD member companies have voluntarily included monitoring of mono- and di-
chlorinated biphenyls, even though these congeners were exempt under older
European regulations.
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Impact of Proposed PCBs Limits on Pigment Market and Supply Chains
The proposed limit would lead to severe disruptions in the pigment market. The challenges in identifying suitable alternatives that meet the necessary technical specifications are significant, as not all pigments can be easily substituted without compromising performance and functionality. Many Colour Indexes are specifically tailored to produce certain hues and properties, making them indispensable for applications in printing, coatings, and other industries. For example, the CMYK printing process relies heavily on specific pigments to achieve consistent colour reproduction.
Restricting the availability of such pigments due to PCBs limits would jeopardize the ability to meet these industry requirements. The proposed regulations could disrupt global supply chains, leading to shortages for Australian industries relying on imported pigments for coatings, inks, and plastics. Pigments from regions like Asia, where PCBs restrictions are less stringent, would not meet these limits, making imports unfeasible.
As a result, downstream productions may shift outside Australia to less restrictive markets, weakening local industry and reducing the global competitiveness of Australian companies. Additionally, the enforcement effectiveness of the proposed PCB limit is called into question when considering that while pigments containing higher levels of PCBs would be restricted from import, finished products containing the same pigments could still enter the Australian market due to dilution effect. This would allow pigments with higher PCBs levels to re-enter the country via imported goods, rendering the intended environmental protection ineffective.
ETAD’s Recommendation
ETAD proposes, therefore, that the Australian Government adopts a more feasible limit of 10 mg/kg, which can be realistically achieved for all color indexes within a three-year timeframe. This threshold is still stringent enough to protect the environment but acknowledges the technical realities of pigment manufacturing. For instance, under Canada’s PCBs Regulations (SOR/2008-273), the presence of PCBs is allowed in pigments if their concentration remains below 50 mg/kg, along with an annual average of 25 mg/kg, a significantly higher threshold than the one currently proposed by Australia.
The proposed limit of 10 mg/kg would ensure that Australian manufacturers and industries remain competitive in the global market. In addition, a transition period of at least three years would be essential to provide sufficient time for manufacturers to adjust and comply with the new regulatory requirements. During this time, manufacturers could implement necessary changes while avoiding sudden and severe disruptions to the supply chain.
Conclusion
ETAD fully supports the Australian Government’s efforts to reduce PCBs levels in pigments. However, the proposed limit of 2 mg/kg is technically unfeasible and would cause severe disruptions to the pigment market and supply chains. ETAD strongly recommends adopting a more realistic limit of 10 mg/kg for PCBs. This approach, along with a three-year transition period, would allow for a smoother adaptation while protecting both the environment and local industries. ETAD looks forward to collaborating on a well-balanced solution that meets both environmental and economic needs.
