Comments on ECHA’s Draft 11th Recommendation for 2-benzyl-2-dimethylamino-4'-morpholinobutyrophenone (EC number: 404-360-3) and references to responses

The present document compiles the comments received during the consultation on the draft 11th recommendation for inclusion of substances in Annex XIV of REACH for 2-benzyl-2-dimethylamino-4'-morpholinobutyrophenone (EC number: 404-360-3). The consultation took place between 2 February 2022 and 2 May 2022.

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 the substance specific entry of the list of Recommendations for inclusion in the Authorisation List (https://echa.europa.eu/recommendations-for-inclusion-in-the-authorisation-list). 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	
3845
2022/04/27	STMicroelectronics,
Company,
Switzerland	STMicroelectronics uses - 2-benzyl-2- dimethylamino[1]4'- morpholinobutyrophenone in limited quantities as an essential ingredient in in specialty chemicals for the photolithography processes
Due to strictly controlled conditions applied in semiconductor manufacturing environment, including double contained distribution system and local exhaust, there is no potential for workers exposure. Moreover, all waste streams are collected and treated. Emissions to air are treated in voc (volatile organic compound) burners, spent chemical liquid waste are collected and sent for incineration.
	A.1.5.3. Use specific considerations
A.1.5.4. Control of risks	
		3845_ST morpholinobutirrofenone ECHA Consultation April 2022 FINAL.pdf

		

II - Transitional arrangements. Comments on the proposed dates
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3845
2022/04/27	STMicroelectronics,
Company,
Switzerland	There is no alternative to current use of 2-benzyl-2- dimethylamino[1]4'- morpholinobutyrophenone in photolithography chemicals in the semiconductor manufacturing process. STMicroelectronics is in touch with the suppliers to identify some alternatives. There is no evidence an alternative will be found soon. Therefore, it is unlikely a substitution plan can be completed before the latest authorization date. As a consequence we believe that the latest application date of 24 months should be chosen.	B.1.1.3. ECHA's proposal for latest application dates
B.1.2. Aspects not considered by ECHA when proposing latest application dates/sunset dates
B.1.2.2. Lack of alternatives, socio-economic aspects
B.2.01. Request LAD of 24 months'	
		See the corresponding embedded attachment in Section I:
3845_ST morpholinobutirrofenone ECHA Consultation April 2022 FINAL.pdf

III - Comments on uses that should be exempted from authorisation, including reasons for that
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3845
2022/04/27	STMicroelectronics,
Company,
Switzerland			
		See the corresponding embedded attachment in Section I: 
3845_ST morpholinobutirrofenone ECHA Consultation April 2022 FINAL.pdf