The Bulgarian Association of the Cement Industry (BACI) thanked the MOEW for the positions expressed so far and the information provided regarding the implementation of Regulation (EU) No 2017/542 of the Commission amending Regulation (EC) No 1272/2008 on the classification, labeling and packaging of substances and mixtures(CLP).

We drew the attention of the MOEW, in the capacity of a national member of the CARACAL Committee, to the following comments and a cement proposal of BACI, as part of CEMBUREAU, the European Cement Association, in respect of the Commission’s proposal for amending Annex VIII of Regulation (EC) No 1272/2008, resulting from the EC workshop on workability, with a cement proposal.

CEMBUREAU, EFCA, EFCC, EMO, ERMCO, Eurogypsum and FEICA, the European associations representing the construction product industries affected by the implementation of the new provisions according to CLP Annex VIII (Regulation (EU) 2017/542)), hereafter‘Annex VIII’, welcomed the workshop organized on 25 September. The workshop allowed fruitful discussion and exchange on the Interchangeable Component Group (ICG) proposal to provide a workable solution. It also provided the possibility for comments on the remaining concerns, specifically for the cement sector.

The ICG concept proposed by the European Commission, together with the additions discussed at the workshop (mode of action approach and ICG update without new UFI), is very helpful for downstream users of MIMs, such as manufacturers of construction products as end-use mixtures and should be taken into account as part of a further amendment to Annex VIII. Nevertheless, the ICG proposal does not solve the problem of cement manufacturers.

Regarding cement, four main points were raised at the workshop as towhy the ICG proposal is not suitable for manufacturers of cement,namely:

1. The variation in the cement constituents necessitates continual adjustments in the way these materials are proportioned together to achieve the desired end product under the harmonized standard EN197-1.
2. Cement is not produced in batches but is a continuous manufacturing process 24h/24h, (refer to Annex I, which describes the cement manufacturing process).
3. The end products defined by EN 197-1 and made of variable components are stored in common silos typically of one to several thousand metric tons.
4. The different constituents of cement have different hazard classifications and can therefore not be covered by one ICG. Even the mode of action approach discussed at the workshop would not solve this problem.

We think that the “Proposal for variable mixtures with reference to standard formulas”, which is one of the German proposals for variable mixtures, would be a practical solution and is complementary with the French proposal. Following this approach,tables with standard formulas for the main types of cements would need to be defined and agreed.

The standard cement formulas approach as presented at the workshop is explained in greater detail in annexes to our statement, along with a proposal of standard formulas for cement and a draft legal text indicating how we believe the standard formulas approach could be implemented in Annex VIII.