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The Directive on Dangerous Substances

Technical Report on the reasons put forward by the Federal Republic of Germany for applying national provisions which divert from the requirements of Directive 97/69/EC, the 23rd adaptation to technical progress of Council Directive 67/548/EEC

Directive 97/69/EC, the 23rd adaptation to technical progress of Directive 67/548/EEC, introduced, among others, the classification and labelling of mineral wool into Annex I (= list of dangerous substances) of Directive 67/548/EEC. During the adoption process of Directive 97/69/EC, all Member States voted in favour except Germany.

For the transposition of Directive 97/69/EC into national legislation Germany notified to the Commission their intention to divert from this Directive concerning the classification and labelling of mineral wool. Germany put forward a range of scientific-technical arguments to underpin the planned transposition.

To respond to the arguments from Germany the Commission mandated a Technical Report from experts in classification and labelling. This Report refuted all arguments presented.

The Report was submitted for peer review to the Scientific Committee for Toxicology, Ecotoxicology and Environment (CSTEE) who issued a critical opinion on both the Technical Report and on the arguments presented by Germany. Among others the CSTEE commented that "A scientific evaluation of either document (the German communication and the Technical report) is difficult due to the lack of references to the used scientific literature."

In accordance with the CSTEE opinion a number of literature references was added to the Technical Report as appropriate.

Full text of the Report (pdf ~80K)