Chlor-alkali Industry Review 2017/2018 - new digital version

Dice thrown for the fourth phase of EU ETS


Directive 2018/410, published in May 2018, lays down the specific rules for the fourth phase of the EU Emissions Trading System (ETS), which relates to the period from 2021 to 2030. The ETS intends to be the EU’s key tool for reducing greenhouse gas emissions. For our industry, it has always been crucial to preserve the possibility to compensate so-called ‘indirect emissions’.

The reason is that our competitiveness may be harmed in case the price for the allowances, paid by the power sector is passed on through elevated electricity prices. The fourth phase of the ETS still allows for indirect compensation via State Aid, with some limitations.

With the upcoming review of the State Aid guidelines in 2020, Euro Chlor will now work with the Cefic Energy & Climate team to keep chlorine production on the compensation list and, with the European Commission, determine the correct benchmark for indirect cost compensation via State Aid.

The EU’s clean energy ambitions; a challenge for us all


The EU is aiming high, not only by striving for an energy mix consisting of 32% renewable energy sources by 2030, but also in counting on an increase in energy efficiency of 32.5% by that same date. These EU-wide targets were agreed during June 2018 trilogue meetings between the European Commission, the Parliament and the Member States. These will now need to be taken up in the Member States’ National Climate and Energy Plans for the upcoming years (up to 2050).

The European Commission’s ‘Clean Energy Package’ aims to place the consumer centrally in the energy market. There will be support for small installations, so that households are also able to participate in the market and self-generate, consume and store any energy they produce. In addition, families will be better informed about energy prices and potential efficiency improvements. The Commission expects this to help to combat ‘energy poverty’. In the package, industry is not seen as a specific, separate player, but merely as a large consumer. Therefore, the challenge is to help streamline the final two pieces of legislation that address the actual energy-market rules.

Particularly for electricity-intensive industries like ours, it is our challenge and our goal to safeguard a reliable and affordable electricity supply.

Biocides work continues with new topics on the horizon


The active substance approval date is rapidly approaching for the disinfectant uses of chlorine, calcium hypochlorite and sodium hypochlorite. By 1st January 2019, biocidal products will also need to be registered and additional studies have been submitted by the Euro Chlor Biocide Registration Groups on the oxidising and explosive properties of these biocides. Work is also underway to provide methods to detect impurities and check for their presence in water as requested by the Member States.

Efforts also continue on characterising chlorates, a decomposition product of the hypochlorite active substances, particularly in food and water. This comes at a critical moment as the European Commission prepares to modify the Drinking Water Directive (98/83/EC) to include a limit for chlorate in potable water. The registration groups are following this very closely and have submitted technical advice to help decision makers during this process.

Approval works on the cooling system and slimicide (preservative, PT11/ PT12) uses are not expected to start until 2020.


Evaluating the safe, effective use of chlorinated alkanes


Support for the REACH CoRAP testing programme, which involves the Euro Chlor Chloro Alkane Product Group, has continued over the last year with some promising results that will assist in further evaluating the PBT (persistent, bioaccumulative, toxic) properties of medium chain chlorinated alkanes (MCCP). The current REACH dossier maintains no PBT status for these substances. Using state-of-the-art methods and international expertise in environmental toxicology and chemistry, the group has been able to show that these versatile chemicals are much more biodegradable than previously thought.

These data are particularly important given the uninformed, premature scrutiny by authorities in areas such as the RoHS (Restriction of Hazardous Substances 2002/95/EC) and Water Framework (2000/60/EC) Directives.

In addition, the group is preparing for an international workshop, to take place in New Delhi on the 29th of November 2018, to discuss the global importance of chlorinated alkanes and their wide range of essential uses, the regulatory and latest scientific developments and risk management strategies.

Mercury, not only part of our past…


On the 2017 Euro Chlor calendar, 11th December marked the official phase-out of mercury-based production technology. Meeting the deadline in a safe and responsible way has been the subject of several meetings and workshops in recent years. Today our attention has shifted to the safe decommissioning of mercury plants and the safe disposal of contaminated materials.

Regulation (EU) 2017/852 on mercury provides the European legal framework for the temporary storage and permanent disposal of mercury and mercury compounds. It allows elemental mercury, that is no longer used in chlor-alkali cells, to be stored temporarily under specific conditions, before its mandatory conversion into mercury sulphide for permanent disposal (e.g. in salt mines).

At this moment, there are two companies providing an operational conversion service in the European Union, as detailed on the Euro Chlor website A third one is still in development and a fourth one located in Switzerland. The Regulation excludes the export of liquid mercury outside the EU. With only two operational installations, the annual conversion capacity risks running short in treating the total amount of mercury remaining within the available (5 year) time-frame. Euro Chlor maintains contacts with the European Commission to discuss the current status and to jointly monitor the progress of mercury stabilisation and disposal.

SCCP exemptions to be assessed under the Stockholm Convention

Euro Chlor continues to monitor the Stockholm Convention for one substance of interest, short chain chlorinated paraffin (SCCP).

SCCP was listed on Annex A (elimination) of the Convention in 2017, with exemptions, and the process has begun for signatory parties to apply for these (e.g. in rubber conveyor belts, waterproof/fire retardant paints, secondary plasticisers). These must be submitted by December 2019 for final evaluation by the technical committee in 2020.

This also has implications for future updates of the Best Available Techniques/ Best Environmental Practices guidance. If the current measures are considered to be unsuitable for managing SCCP, then these may need to be updated.


A decade of REACH

In 2018, REACH passed the third and final milestone of chemical registration for substances produced in volumes over one tonne. Whilst the administration of the various chlor-alkali REACH consortia passed to ReachCentrum at the end of 2012, the Euro Chlor Secretariat remains involved in monitoring REACH issues at a low level via the dedicated REACH project team.

Euro Chlor registered substances were successfully finalised ahead of the 2010 deadline but dossier updates remain an important activity for the entire chemical industry. The REACH caustic soda and chlorine successfully updated both dossiers in 2018.

This proactive work demonstrates the value that our industry places on these dossiers as sources of correct information about our key substances and is a credit to the hard work of all those Euro Chlor members concerned.



Methylene chloride is still subject to substance evaluation under CoRAP, as it was alleged in 2016, by Italy, to have endocrine disrupting (ED) properties.

The ChlorSolv REACH Consortium sent a summary document to Italy in early June 2017, using a weight of evidence approach from existing studies to demonstrate that the substance does not have such properties. The consortium is awaiting feedback from Italy, expected within 1 year from the commenting deadline.

For chloroform, the ChlorSolv REACH Consortium conducted a new survey of data from industrial producers and users to improve the environmental exposure assessment. The new assessment, performed under current REACH rules, confirmed that all industrial uses are safe and that any unavoidable discharges into sewage treatment plants pose no environmental risk. The joint REACH dossier will now be updated with these results.

ECSA: Montreal Protocol and the EU ODS regulation


The UN has begun revising the Montreal Protocol on the protection of the ozone layer and will include halogenated very short-lived substances (VSLS).

Methylene chloride (DCM) belongs to these substances with an atmospheric lifetime of 0.4 years. NGOs are strongly advocating for strict global usage restrictions or even bans of VSLS substances under the Montreal Protocol. Scrutiny of DCM was triggered by an article in Nature, which reported increasing amounts in the atmosphere and also proposed that this could delay the ozone layer repair.

However, this assumption came from unrealistically high growth rates of DCM production, particularly in China. As various media reported on the article, ECSA replied to Chemistry World and other outlets and consulted Dr. Archie McCulloch, who published a paper showing how DCM actually has a negligible effect on stratospheric ozone depletion. Any DCM that does get into the stratosphere rapidly decomposes in the lower stratosphere. The contribution of anthropogenic and natural DCM emissions to the overall total stratospheric chlorine is <1%. This led to a presentation by ECSA, supported by HSIA, at a side event of the Montreal Protocol meeting in November 2017. As most emissions of the solvent originate from developing countries, where DCM is used mainly in emissive applications (particularly in India and other parts of Asia), further regulatory action should focus on minimising emissions in these countries. This has already begun in China.

In parallel, in mid-2017, the EU Commission began the process of revising the EU Ozone Depleting Substances (ODS) regulation, which implements the Montreal Protocol in the EU. ECSA is a recognised stakeholder of this process, and members have provided extensive feedback on the consultation process to simplify and streamline the regulation without comprising its goal to protect the ozone layer.

In mid-2017, the EU Commission began the process of revising the EU ODS regulation

ECSA works with the Cefic PMT task force and German Industry Association (VCI) on advocacy efforts to oppose the PMT concept for SVHC identification


ECSA: UBA PMT approach


The German Environment Agency (Umweltbundesamt, UBA) has published their “Assessment of persistence, mobility and toxicity (PMT) of 167 REACH registered substances” with the aim of protecting drinking water resources in Germany.

UBA has set conservative criteria that are alleged to match the properties of perchloroethylene (PER) and trichloroethylene (TRI), meaning that they appear high on the list. UBA also aims to establish PMT as an “equivalent concern” under Article 57 of REACH, and to use PMT substances as substances of very high concern (SVHC) for inclusion on the candidate list for authorisation under REACH. To test this, UBA are starting with the first 9 substances of the report which include these solvents.

ECSA does not consider such a classification as being the right tool to improve drinking water quality especially as TRI is already listed in Annex XIV (authorisation) and PER is handled today almost exclusively in closed systems with no intentional emission to water or soil.

ECSA has therefore prepared a position paper and works with the Cefic PMT task force and German Industry Association (VCI) on advocacy efforts to oppose the PMT concept for SVHC identification. Major arguments include how the PMT concept is too conservative and not considered equivalent to PBT as defined by REACH, and how there is already sufficient regulation in place for drinking water protection (including the drinking water directive, water framework directive, and national water protection legislation).