On 24 June 2016, the Official Journal of the European Union published Regulation (EU) 2016/1017 on the amendment of Entry 65 of Annex XVII to REACH Regulation as inorganic ammonium salts. It provisions that Inorganic ammonium salts shall not be placed on the market, or used, in cellulose insulation mixtures or cellulose insulation articles after 14 July 2018 unless the emission of ammonia less than 3 ppm. This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.
On 14 August 2013, the French Republic informed the Commission, the European Chemicals Agency and the other Member States that it had adopted a provisional measure on 21 June 2013 to protect the public from exposure to ammonia released from cellulose wadding insulation materials with ammonium salts used in buildings, and initiated the restriction procedure by submitting to the Agency an Annex XV dossier on 18 June 2014 followed by examination by the RAC and SEAC.
65. Inorganic ammonium salts
1. Shall not be placed on the market, or used, in cellulose insulation mixtures or cellulose insulation articles after 14 July 2018 unless the emission of ammonia from those mixtures or articles results in a concentration of less than 3 ppm by volume (2,12 mg/m3) under the test conditions specified in paragraph 4.
A supplier of a cellulose insulation mixture containing inorganic ammonium salts shall inform the recipient or consumer of maximum permissible loading rate of ellulose insulation mixture, expressed in thickness and density.
A downstream user of a cellulose insulation mixture containing inorganic ammonium salts shall ensure that the maximum permissible loading rate communicated by the supplier is not exceeded.
2. By way of derogation, paragraph 1 shall not apply to placing on the market of cellulose insulation mixtures intended to be used solely for the production of cellulose insulation articles, or to the use of those mixtures in the production of cellulose insulation articles.
3. In the case of a Member State that, on 14 July 2016, has national provisional measures in place that have been authorised by Commission pursuant to Article 129(2), provisions of paragraphs 1 and 2 shall apply from that date.
4. Compliance with the emission limit specified in the first subparagraph of paragraph 1 shall be destrated in accordance with Technical Specification CEN/TS 16516, adapted as follows:mon
(a) the duration of the test shall be at least 14 days instead of 28 days;
(b) the ammonia gas emission shall be measured at least once per day throughout the test; (c) the emission limit shall not be reached or exceeded in any measurement taken during the test;
(d) the relative humidity shall be 90 % instead of 50 %;
(e) an appropriate method to measure the ammonia gas emission shall be used;
(f) the loading rate, expressed in thickness and density, shall be recorded during the sampling of the cellulose insulation mixtures or articles to be tested.
CTI advises EU exporters to keep an eye on any update or amendment to REACH Regulation as it is closely associated with international trade. Companies should pay attention to high-risk products, components, ensure that products meet the requirements of inorganic ammonium salts control, reduce the risk of the product being punished.