Instead the more sophisticated and documented submission of the applicant should prevail. Other comments Chroma & Hue. We agree to the statement: “Since chroma and hue are specific to a pigment the search for a 1:1 replacement cannot succeed”, which confirms our view that PY.34 and PR.104 are irreplaceable. Opacity, Heat stability, Weather fastness. VdMi basically confirms our argument in our AoA. VdMi states that each of these properties may be matched to the superior quality of PY.34 or PR.104 by smart combination of different (in)organic pigments, but each of these combinations will most probably lead to compromising one or more of the other performance properties. Dispersibility. We do not agree to the statement : “In principle inorganic, hybrid pigments and dry pigment preparations are easier to disperse compared to organic pigments”. Hybrid pigments are often a combination of organic and inorganic pigments. Organic pigments are typically harder to disperse compared to inorganic pigments. As such any hybrid pigment will be as difficult to disperse as the organic component it contains. We would agree that inorganic pigments and pigment preparations are easier to disperse than organic pigments. However, PY.34 and PR.104 are always the easiest to disperse compared to any of the potential alternatives presented. Reference Submitter: Alternative: number Type Generic EC CAS Description of technical and date: name alternative and Labelling Ref.No: Affiliation: pigment CLP 398 BehalfOfACompany mixture As stated in Date: Type/Role in the Appendix I of 2014/04/08 supply chain: the Manufacturer document. Name of org/company: Confidential Country: Confidential Applicants’ response:
Instead the more sophisticated and documented submission of the applicant should prevail. Other comments Chroma & Hue. We agree to the statement: “Since chroma and hue are specific to a pigment the search for a 1:1 replacement cannot succeed”, which confirms our view that PY.34 and PR.104 are irreplaceable. Opacity, Heat stability, Weather fastness. VdMi basically confirms our argument in our AoA. VdMi states that each of these properties may be matched to the superior quality of PY.34 or PR.104 by smart combination of different (in)organic pigments, but each of these combinations will most probably lead to compromising one or more of the other performance properties. Dispersibility. We do not agree to the statement : “In principle inorganic, hybrid pigments and dry pigment preparations are easier to disperse compared to organic pigments”. Hybrid pigments are often a combination of organic and inorganic pigments. Organic pigments are typically harder to disperse compared to inorganic pigments. As such any hybrid pigment will be as difficult to disperse as the organic component it contains. We would agree that inorganic pigments and pigment preparations are easier to disperse than organic pigments. However, PY.34 and PR.104 are always the easiest to disperse compared to any of the potential alternatives presented. Reference number and date: Submitter: Alternative: Type Generic name EC CAS Description of technical alternative and Labelling Ref.No: 398 Date: 2014/04/08 Affiliation: BehalfOfACompany Type/Role in the supply chain: Manufacturer Name of org/company: Confidential Country: Confidential pigment mixture CLP As stated in Appendix I of the document. Applicants’ response:
a4a_comment_response_87_0012-10_attachment_en.docx