Important changes to HOCNF requirements
Status of OECD 302 Inherent Biodegradability Data
Subject to confirmation by the OSPAR Heads of Delegation Meeting in September, it was agreed at the OIC 2010 meeting that inherent biodegradability data (such as that obtained from the OECD 302 test) will no longer be considered acceptable at the discretion of a contracting party for the registration of offshore chemicals from January 1st 2011. This change further harmonises HMCS with REACH. As a result, after this date all products that rely upon OECD 302 data for their -registrations will be issued with substitution warnings, UNLESS new biodegradation data from allowable methods is provided beforehand that indicates that the substitution warning is not warranted.
We advise you to check whether this change affects your products directly, and make suitable arrangements where relevant. In addition, it should be noted that certain products may be indirectly affected by this change, i.e. those which currently avoid the application of a substitution warning as a result of OECD 302 data through the United Kingdom's use of the Global Approach.