19/02/2020 (revised 11/03/2020)
The Cobalt Institute (CI) takes note of the EU's updated harmonised classification rules for cobalt metal, including a temporary Generic Concentration Limit (GCL) of ≥ 0.1 %. The new rules will enter into force on 9 March 2020 and will start to apply from 1 October 2021. The cobalt industry is working with its downstream users to ensure an effective implementation of the new harmonised classification.
The CI continues to firmly believe that EU regulation should focus on the established hazard concerns linked to the inhalation of cobalt metal. Regrettably, despite existing data indicating the safety of dermal and oral exposure to cobalt metal, the new harmonised classification is not limited to inhalation. As a consequence, the cobalt industry plans to invest significant additional resources to generate new scientific evidence to conclusively prove that cobalt metal can be used safely once exposure via inhalation is controlled.
The CI welcomes the European Commission's recognition, through the temporary GCL, of the need to further refine the methodology for deriving concentration limits for inorganic materials such as cobalt metal. We strongly encourage EU and member state authorities to continue to engage in the expert group which has been established to review this methodology under the European Chemicals Agency. In the meantime, it will be important in our view to maintain the current GCL, the appropriateness of which we are confident will be confirmed by the ECHA review.
The CI and its members will continue to work with EU and member state regulatory authorities to ensure the safe and sustainable use of cobalt metal, a critical raw material for EU manufacturing.
The CI represents producers, users, recyclers, and traders of cobalt globally.