EU legislation on color could make you see red. Confusion reigns supreme.
Tony Gaukroger in his facility next to a stack of 25-kg bags of masterbatch.
Tony Gaukroger ([email protected]) is managing director of Colour Tone Masterbatch Ltd. (Bedwas, Wales; www.colourtone-masterbatch.co.uk), a specialist masterbatch supplier offering universal and polymer specific masterbatches for commodity and engineering polymers as well as custom additive blends.
Adding color to plastics has always been a science rather than an art, but with increasingly invasive European Union (EU) legislation controlling the use of pigments and additives, the process is in danger of becoming too complex. Choosing the correct colors that meet legal and application requirements, while satisfying cost parameters, are critical issues for processors. The problem is that the EU rules do not always appear to follow any logical path. The science is inexact and the interpretation of it is almost an art.
For example, it is obligatory to use certain pigments in some applications while lower-cost alternatives are acceptable in other areas. Processors who choose the wrong colorants may find that their end product is not fit for purpose. Worse still, they could be illegal. The directives present a major headache for end users, processors, compounders and masterbatch manufacturers.
There is nothing wrong with the original purpose of the directives, which was to protect consumers as well as the environment. The problems occur in their interpretation and application. Its a minefield where confusion reigns supreme.
Laws based on nomenclature, not logic
Consider the use of a lead chromate yellow to color PP beach bats (Ed. note: for a game combining variants of table tennis and beach volleyball). In this application the pigment would be illegal if the product was classified as a toy. Call it sports equipment and the pigment would be acceptable. Similarly, a polyamide molding colored with food-approved cadmium red would be perfectly acceptable in a food processing product as long as it did not conflict with another directive covering the use of colors in electrical appliances.
Energy efficiency and environmental concerns continue to be headline news around the world. In Europe, where landfill sites are at a premium, there is a sharp focus on recycling and it is not surprising that the directives take account of end-of-life issues, so manufacturers must ensure they use recyclable colorants. Chrome yellow pigment could not, for example, be used in electrical, automotive, or packaging applications because it would offend certain recycling conventions.
As mentioned earlier, product classification is critical and yet there are serious anomalies in the directives. Is a videocassette box packaging or is it a product? Is a yellow grow bagâa PE bag containing peat, where seeds are implanted through the outer skinâpart of the product or is it just packaging of garden peat?
What can be done? We advise customers to protect themselves by taking a number of precautions. Implementing a system that will track current and future legislation is essential. Companies can use various means to monitor developments in their specific areas by following press articles and linking with industry trade associations. It is also essential that everyone in the supply chain agree to a process that facilitates the accurate classification of the end use of the items they intend to manufacture.
Masterbatch companies especially have to know their way around the legislation. In order to create cost-competitive, legally compliant formulations, they have to rely on accurate descriptions of a products intended end use. Part of ISO 9001:2000 accreditation ensures everyone makes products that are legal and fit for purpose. Ambiguous EU legislation simply makes this more difficult to achieve.
Any manufacturer intending to sell goods in Europe cannot afford to ignore this legislation. It is worth noting that the rules apply now, so dont be tempted to use old stocks of masterbatches without first talking to an expert on the subject.
If you would like to contribute to As I See It, contact Editor-in-Chief Matthew Defosse at edito[email protected].