Saatja: "Elisa Consoli" <
[email protected]>
Saaja:
[email protected]
Teema: [Chemicals] ASD clarification suggestions on Terphenyl, hydrogenated restriction ahead of the REACH Committee discussion
Kuupäev: 2026-06-23 15:24
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Dear Ms. Ulm,
I am reaching out on behalf of ASD, the Aerospace, Security and Defence
industries association of Europe, to share the attached letter outlining
the industry suggestions on the pending Terphenyl, hydrogenated
restriction ahead of the REACH Committee discussion scheduled for 25 June.
We would be grateful if you could share the attached document with the
Estonian representative at the REACH Committee.
Should you have any questions, please do not hesitate to reach out to us.
Kind regards,
Elisa
Elisa Consoli
REACH & Chemicals Manager
Aerospace, Security & Defence Industries Association of Europe
Mobile. <tel:+32%20(0)%2049%2062%2066%20072> +32 (0) 49 62 66 072
Email. <mailto:
[email protected]>
[email protected]
Rue du Trône 100 | 1050 Brussels
<https://www.asd-europe.org/> www.asd-europe.org
Brussels, 22 June 2026
Ms. Reet Ulm
Delegate of the Estonian Permanent Representation to the EU
Rue Guimard, 11/13
1040, Brussels, Belgium
Dear Ms. Ulm,
RE: ASD clarification suggestions on Terphenyl, hydrogenated restriction
ahead of the REACH Committee discussion
The Aerospace, Security and Defence industries association of Europe (ASD) welcomes the European
Commission’s proposal following the 2023 ECHA opinion on the proposed REACH restriction of Terphenyl,
hydrogenated (PHT). While we are pleased to see many of our industry’s specificities and key priorities being
reflected in the decision proposal, we would like to put forward some questions and suggestions to ensure the
interpretation of the provisions is clear in advance of the upcoming REACH Committee discussion on the file
expected for 25 June.
In general, ASD is concerned that the different language between the paragraphs might lead to unharmonized
interpretation of the provisions directly relevant to Aerospace. Specifically, while paragraph 2 of the proposed
Annex XVII amendment refers to a 10-year deferral for “civilian aerospace applications”, point (a) of paragraph 4
of the same annex refers only to the “civilian aircrafts” placed on the market in virtue of the provisions under
paragraph 2.
In order to avoid any confusion, we would urge the co-legislators to ensure consistency in language by using
“civilian aerospace products” rather than limiting the provision to the aircrafts. The suggested language would
ensure that also the relevant aerospace parts and components (original equipment or spare parts) are covered
by the provision, as well as other civilian aerospace products such as ground equipment (e.g. radars) and
spacecrafts or satellites.
Moreover, we would suggest clearly outlining that maintenance, repair and overhaul (MRO) should be considered
as covered by the provisions under paragraphs 2 and 4 due to the requirement to ‘repair as produced’ covering
aerospace products.
Aerospace, Security and Defence Industries Association of Europe | Rue du Trône 100 I 1050 Brussels
Phone: +32 2 775 81 10 I
[email protected] I www.asd-europe.org
Conclusion
Based on the justifications provided above, we urge the co-legislators to:
• Replace in point (a) of paragraph 4 “civilian aircrafts” with “civilian aerospace products” for
alignment;
• Clarify that maintenance, repair and overhaul (MRO) activities are also covered by the provisions in
paragraphs 2 and 4 of the Annex.
ASD remains ready to respond to any follow-up questions.
Yours sincerely,
Camille Grand,
Secretary General of ASD
Aerospace, Security and Defence Industries Association of Europe | Rue du Trône 100 I 1050 Brussels
Phone: +32 2 775 81 10 I
[email protected] I www.asd-europe.org