BASF and automotive industry group agree substitution criteria

German chemical giant BASF and the European Automotive Industry Association (Acea) have agreed on a set of criteria for selecting ‘non-regulated’ alternative substances to help vehicle manufacturers avoid so-called regrettable substitutions. The criteria are an update of Acea’s original version, which it presented to the European Chemical Council (Cefic) and its members early last year. The association’s aim is for chemical manufacturers to use the criteria when identifying alternatives to supply in place of regulated substances. However, since last year, Acea has worked with chemical manufacturers, mainly BASF, to agree on the criteria and an exact wording. The criteria (see box) now puts more emphasis on communication between the automotive industry and chemical manufacturers when developing a solution to a regulated substance that needs replacing. BASF’s senior advocacy manager for chemicals in products, Dr Uwe Blumenstein, told Chemical Watch the main points that the chemical giant wanted to instil in the criteria were to agree on a communication process for substances and their hazard profiles, and define a “safe harbour” status for an alternative. “These are the main areas where the criteria differs from the original set released a year ago,” he said. Dr Blumenstein said that while BASF has been the first to agree on the criteria, and will begin using it, others in the chemical industry are also supporting the them. He did not say which companies. He is “hopeful” that the criteria will become a common standard for the industry, otherwise it “won’t be effective in addressing the issue of regrettable substitution”. Timo Unger, Hyundai Motor Europe’s environmental affairs manager, told Chemical Watch that there are an increasing number of vehicle manufacturers intending to include the criteria in their processes, such as in the purchase conditions or supplier specifications. “This has not happened yet, but discussions are happening and some manufacturers are on board,” he said. Discussions have also involved other chemicals and downstream companies brought together through Cefic’s value-chain outreach working group.


Chemicals used in the automotive industry should:

  • have a complete registration and toxicological-profile according to regulatory request. Relevant data gaps (for example, no testing on the substitute) should be highlighted. It should not have the same or similar adverse effects as the original substance. And assessment results are needed, whether the substitute has the same hazard/toxicological profile and verification by testing. It should also be “less hazardous” than the original substance, which is to be defined case by case;
  • have a listing in all mandatory global chemical inventories, for example TSCA, IECSC, KECI, ENCS, PICCS. If not, the producer will inform the downstream users about known potential importer duties with relevant data;
  • not be already prohibited/restricted or intended to be prohibited/restricted for its automotive use or not be listed on GADSL/Glaps. “They can still be regarded as sustainable if the properties don’t meet the SVHC criteria and are not expected to meet them because all relevant test data, according OECD guidelines, are available”;
  • be available or have the potential to be made available in amounts sufficient to supply customers’ needs; and
  • fulfil typical technical and supply related customer requirements.

Chemical Watch, 5 April 2018 ;

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