Based on comments submitted by ILMA and other stakeholders, Europe’s chemicals agency is now calling for a 10-year phaseout for medium-chain chlorinated paraffins used in all metalworking fluids (MWFs) in the EU, instead of its original recommendation of two years for water-based MWFs and seven years for straight oils.

The European Chemicals Agency’s (ECHA) proposed ban affects medium-chain chlorinated paraffins (MCCPs) and other substances with carbon chain lengths from C14 to C17. Earlier this week, ECHA’s Socio-Economic Analysis Committee (SEAC) revised its opinion on the ban.

“This is a significant development for ILMA members and their customers, particularly those in the EU,” said ILMA CEO Holly Alfano. “We are pleased that the SEAC recognizes the problems in formulating away from MCCPs for many products, including essential ones in the medical, aerospace and defense industries.”

ECHA proposed banning MCCPs in September 2022, when it released an Annex XV report under the EU’s REACH Regulation. ILMA submitted extensive comments on the report in March, broadly arguing against an EU-wide MCCP ban.

Under the REACH process, the SEAC reviews each Annex XV report. The committee released a draft opinion on the proposed ban in June, largely endorsing the Annex XV report and maintaining that the effects of the ban would be manageable. It recommend at that time that oil-based or straight MWFs be given a seven-year exemption (or “derogation”) period because of the lack of drop-in replacements, while the derogation for water-based MWFs be limited to two-years because of environmental concerns.

ILMA submitted a second set of comments to the SEAC in August, asserting that banning MCCPs would force the closure of various metalworking processes that produce essential products in the medical, aerospace and military sectors. These products include heart stents, hypodermic needles, ammunition shell casings, bolts, fasteners and others. Given the importance of these products, ILMA argued for an indefinite exemption period.

“ILMA’s team of member company reps, consultants, counsel and staff saw the original SEAC recommendation as a ‘line in the sand’ and worked tirelessly along with UEIL and others to prepare the Association’s comments,” Alfano said. “Under the SEAC’s timeline, MCCPs will be permitted to remain in use in MWFs until about mid-2036.

“While an indefinite exemption period would have been preferred, this extension gives the industry valuable time to devise MCCP alternatives,” Alfano added. 

While ECHA is not mandated to follow the SEAC’s recommendations, it generally does so. ECHA is expected to release the final restriction report in mid-2024. It is possible that the release may be delayed until later next year because of the European Parliamentary elections in June.