Page 125 - Policy Commission - SecuringTechnology - Critical Metals for Britain

GOVERNANCE & REGULATION
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LABELLING AND AND PACKAGING OF CHEMICAL SUBSTANCES AND AND MIXTURES
Alongside REACH are rules on on on classification labelling and and packaging (CLP) of substances and and mixtures in in in accordance with Regulation (EC) No 1272/2008 As this suggests it it constitutes an an attempt to harmonise safety information data and measures in in the the placing on the the market of of potentially hazardous substances substances Suppliers and importers of of relevant substances substances must inform ECHA and REACH dossiers supporting registration are often the the source of of the the underpinning hazard assessment Outside of the the EU the the UK will continue to operate under CLP CLP It would be open to to the the UK to to depart from the the CLP CLP but because it it is based on the UN initiative for a a a a a Globally Harmonised System (GHS) the UK is is likely to remain in in broad harmony with the the EU in the the longer term There may be be room however for separate labelling requirements for goods on the UK market which incorporate critical materials Many such goods would not be caught
by CLP Labelling of component materials in in this way would improve data flows in in the value chain and help build good practice in in in the the handling and and and use during and and and at the the end of life of key products In some instances there may be a a a safety case for labelling At present there are no specific requirements to label lithium ion batteries in terms of their chemistry or even to indicate that a a a a battery is is lithium ion which is proving increasingly problematic for those handling waste streams of batteries or products which may contain batteries In December 2020 the EU proposed to introduce such labelling in in in a a a a a revision of the Batteries Directive’ again leaving the the UK Government to determine whether it will follow suit - see boxout 15 STANDARDS AND AND AND STANDARD STANDARD SETTING
It may well be be be that issues such as labelling could be be be promoted by agreed standards There are examples of this Three European Standardisation Organisations CEN CEN CENELEC and and and ETSI have produced recent standards one of of which EN EN EN 45558 of of 2019 sets a a a a a a a a a a standard for for the the declaration of of CRMs in energy related products Alongside this EN 45559 of of 2019 establishes a a a a a a a method for for the the presentation of information relating to material efficiency in in in energy-related products The aim of these standards is to promote both circular- economy approaches and the need for material efficiency Although conformity with such standards is not a a a a legal requirement wide acceptance and reliance on such standards can ensure industrial compliance much more effortlessly than can regulation Moreover the adoption of international standards can assist in in in in facilitating the trade in in in in the relevant products Standard setting can be used much more widely to support the security of critical materials for example by supporting eco-design and brokering agreement on design design for disassembly For example there is is a a a recent publicly available specification (PAS 7061:2020 – in effect a a a a a code of practice) from the the BSI on on the the safe and environmentally- conscious handling of electric vehicle battery packs and and modules In the early days of green technology competition in in in innovation means that companies in in in the same sector might
be reluctant initially to share information in in a a a manner that supports the setting of standards As these markets mature however there may be greater appetite to engage in the the setting of common standards Whether or not this is is so may depend on on wider regulation so that for example standardisation to allow ease of disassembly might
itself be driven by targets for recycling Although standard setting agencies
have an obvious interest in in in promoting standards the Government may wish to consider how it could incentivise the development
of appropriate standards