Ref.No: 178 Affiliation: SubsOnItsOwn Chrome Titanate CLP Date: 2014/03/20 BehalfOfACompany Not Classified Type/Role in the supply chain: Manufacturer Name of org/company: Confidential Country: Confidential Applicants’ response: Applicants reply to comments 177, 178 Contributing third party: Confidential ECHA consultation numbers 0012-01 and 0012-03 DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, namely PBr.24. DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PBr.24 simply lacks the shade functionality, chroma and colour strength to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism. We agree to another important aspect of the comment, being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PY.34 will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU. DCC notes that the submission supports its application for authorisation for the continued use of PY.34. Reference Submitter: Alternative: Attachments: number and Type Generic name EC CAS Description Classification date: Number Number of technical and Labelling alternative Ref.No: 176 Affiliation: SubsOnItsOwn Nickel Titanate CLP Date: 2014/03/20 BehalfOfACompany Not Classified Type/Role in the supply chain:
Ref.No: 178 Date: 2014/03/20 Affiliation: BehalfOfACompany Type/Role in the supply chain: Manufacturer Name of org/company: Confidential Country: Confidential SubsOnItsOwn Chrome Titanate CLP Not Classified Applicants’ response: Applicants reply to comments 177, 178 Contributing third party: Confidential ECHA consultation numbers 0012-01 and 0012-03 DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34, namely PBr.24. DCC notes that the comments submitted are in favour of approving the authorisation of PY.34 to allow for the continued use of PY.34. In support of this submission, PBr.24 simply lacks the shade functionality, chroma and colour strength to be considered a viable PY.34 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism. We agree to another important aspect of the comment, being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PY.34 will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU. DCC notes that the submission supports its application for authorisation for the continued use of PY.34. Reference number and date: Submitter: Alternative: Attachments: Type Generic name EC Number CAS Number Description of technical alternative Classification and Labelling Ref.No: 176 Date: 2014/03/20 Affiliation: BehalfOfACompany Type/Role in the supply chain: SubsOnItsOwn Nickel Titanate CLP Not Classified
a4a_comment_response_0012-03_part2_en.docx