The Committee for Socio-economic Analysis (SEAC) supports France and Sweden’s proposal to restrict the use of skin sensitizing substances in clothing, footwear, and other articles with similar skin contact. If adopted, the restriction will prevent many people from developing new skin allergies while also relieving the symptoms of many of those who already have them. This is expected to result in health benefits equivalent to at least €708 million per year.
SEAC adopted its final opinion on France and Sweden’s proposal to restrict skin sensitizing substances in textile, leather, synthetic leather, hide, and fur articles that are placed on the market for the first time. This follows an earlier opinion by the Committee for Risk Assessment (RAC) in March 2020. Both committees concluded that an EU-wide restriction is the most appropriate means to address the risks to EU citizens. In addition, SEAC concluded that the expected benefits and costs to society of the proposal mean that it is likely to be proportionate.
Skin sensitization is a health effect that leads to lifelong sensitivity to a specific allergen. Currently, there is growing concern about skin sensitization from exposure to chemicals in textile and leather products: It is estimated that up to 5 million people in the European Economic Area are already sensitized, and up to 180 000 new cases occur each year.
The proposed restriction covers substances that have a harmonized classification as skin sensitizers under the Classification, Labelling and Packaging (CLP) Regulation such as chromium VI, nickel, and cobalt compounds. It also proposes to restrict some dyes that are considered to have skin sensitizing properties, but which do not have a harmonized classification. The proposal introduces a link with the CLP Regulation meaning that any substance that is classified as a skin sensitizer in the future under CLP would automatically be covered by the restriction. When substances are automatically added to the restriction, SEAC recommends a transitional period of three years between classification and the conditions of the restriction taking effect to allow manufacturers to adapt.
If adopted by the European Commission, the restriction will prevent many new skin allergies while also relieving the symptoms of many people who already have them. This is expected to save European society at least €708 million a year in reduced healthcare costs, productivity losses (e.g. due to sick leaves), and welfare losses (in terms of reduced quality of life due to the allergy). The raw material costs for industry to replace the chemicals are estimated to be up to €23.8 million per year. There will also be costs related to reformulation, testing, and enforcement.
Following SEAC’s adoption, the opinions of both RAC and SEAC as well as the proposal of France and Sweden will be sent to the European Commission, which will take the decision together with the EU Member States.
