General Assembly Meeting Thursday, May 5th 10:00 – 13:00

General Assembly Meeting - 2022

Highlights from the General Assembly Meeting

The 2022 General Assembly meeting which took place virtually on May 5th discussed general issues related to the smooth running of the consortium as well as possible threats emanating from ECHA/the Commission by way of potential Restrictions/Authorisation related to the use of several Mn substances within the EU amongst other things.

The meeting saw the following decisions taken

The GA agreed a on methodology to redistribute income from Non-EU REACH data sales. MARA’s assets in the form of study reports are being sold for the purposes of Non-EU regulatory compliance in the hope of sharing knowledge on the toxicity profile of Mn-based substances in view of a worldwide harmonising the classification. The GA agreed that if the entire industry use the same data – then industry will settle for the same classification.

MARA’s Office: The GA discussed the need of an actual office versus a virtual office from a financial standpoint. Considering that work was still effective during the pandemic lockdown, it was clear that a virtual office will reduce cost without affecting the quality of work carried out by the Consortium. To this end, the GA approved for MARA to seek advice from the French authorities on the possibility of a Not-for-profit organisation to be domicile virtually.

Harmonised Categorization of Slags across the EU: The GA approved a way to fund this special project. The project which considers the present regulatory constraints on the use or disposal of slags across the EU to be non-harmonised is aimed at creating a level playing field guided by a harmonised regulatory standpoint for all players within the EU. The project intends to use a robust socio-economic analysis and lobbying of the authorities to achieve its goes.

Several Manganese Substances - Possible Restriction and/or Authorisation

As REACH enters deeply into its E phase (Evaluation), the review of dossiers on their own or in groups by the ECHA has prompted several compliance checks requests which for the past years have been addressed by the Mn Consortium via updating dossier waivers, improving/strengthening of the readacross justifications or conducting new studies as the case may be. However, lately although no new specific request has emanated from ECHA's reviews, more worrisome concerns have been published in the ECHA Assessment of Regulatory Needs report (7 December 2021, version 1.0 [1]). 

The report covers several organic and inorganic substances with 14 Mn-based substances referred to as “Simple Manganese Compounds" and highlight concerns regarding reproductive potential, neurotoxic potential (STOT RE) and aquatic toxicity potential for the 14 substances listed (

As MARA spent Q1 2022 reviewing, analysis and looking for possible solutions to address the issues raised in this report by way of recruiting experts in the areas of concern (a task force) and conducting a SWOT analysis in the dossiers both within the content of each dossier and the consistency or lack of it across dossiers, ECHA published another document called the restriction road map http://COMMISSION STAFF WORKING DOCUMENT Restrictions Roadmap under the Chemicals Strategy for Sustainability). In this report Mn substances are in pool 2 - potential restriction. The report highlights similar concerns as the assessment of regulatory needs report including some mention of Endocrine disruption potential for the said Mn substances.

While dates and members states working on the aforementioned concerns/activities are yet to be determined, MARA must be proactive not only in terms of updating ALL its lead dossiers but also must work hand in hand with the regulators to address all potential concerns by way of issuing position papers or face-of-face meetings. A clear workplan will made available to all registrants. 

We look forward to a very busy second part of the year and request that all registrants remain alert, provide MARA with any information requested and send in their contributions promptly in cash or in kind (company experts could join task forces) as the need arises. 

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