Comments on ECHA’s Draft 10th Recommendation for Disodium octaborate (EC number: 234-541-0) and references to responses

The present document compiles the comments received during the consultation on the draft 10th recommendation for inclusion of substances in Annex XIV of REACH for Disodium octaborate (EC number: 234-541-0). The consultation took place between 5 March and 5 June 2020.

For each of the comments there is also a reference to specific section(s) of a document containing the responses to comments (“Response document”, available at https://echa.europa.eu/documents/10162/13640/10th_recom_respdoc_disodium_octaborate_en.pdf). The responses in the Response document are arranged by thematic block and level of information (see more detailed explanations at the beginning of that document.

Public version

Content
	
I - General comments on the recommendation to include the substance in Annex XIV
II - Transitional arrangements. Comments on the proposed dates
III - Comments on uses that should be exempted from authorisation, including reasons for that

I - General comments on the recommendation to include the substance in Annex XIV
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3522
2020/06/04	European Borates Association,
Industry or trade association,
Belgium	The scoring and, thus, the prioritisation of disodium octaborate in the 10th draft recommendation is in accordance with the REACH regulation and the ECHA Guidance on prioritisation. Nevertheless, we wish to question the prioritisation of a substance where substitution is not possible for more than 90% of its uses. This could have been identified via a proper RMOA, regulatory management option analysis, but such one is still missing for now.
Please see further the document attached.	A.1.5.1 Potential other regulatory actions

A.1.5.4 Control of risks

A.2.01	Proper RMOA for disodium octaborate missing

A.2.02	Substitution as aim of authorisation cannot be reached for essential uses in fertilisers
	
		3522_EBA comments - DO ECHA prioritisation.pdf
		
3538
2020/06/04	Brenntag Quimica SAU,
Company,
Spain	We support the comments provided by the European Borates Association	See responses referred to in comment #3522	

II - Transitional arrangements. Comments on the proposed dates
No comments received.

III - Comments on uses that should be exempted from authorisation, including reasons for that
No comments received.