The GPMA Proposes A Delay In The Implementation Of GBL And 1,4-BD Solvent Regulations For Digital Printing Inks
The Graphics and Print Media Alliance (GPMA) consists of trade associations representing companies operating in the graphics and print media industry supply chain.
Between them, they represent an industry of over 7,400 companies, the majority of which are SMEs with an annual turnover of £11.6 billion which employs approximately 105,000 people.
They say that new regulations for GBL & 1,4-BD that are due to come into effect in Mid-June will have a truly widespread detrimental effect on the UK printing industry.
Because many of the affected businesses by the new GBL and 1,4-BD regulations are SMEs that are currently in a stage of fragile recovery following the major financial impact of Covid-19 – they are not in a position to be able to invest in alternative printing equipment that does not use GBL affected ink.
They are also ill-equipped to afford (or logistically cater for) the current licencing requirements.
As a result, the GPMA suggest to government the following options for consideration.
• The applicability of the legislation is delayed allowing for a full and thorough
consultation with Industry;
• A technical evaluation of the abilities of illicit users to extract useable substance from product mixtures is commissioned by Government with contribution from Industry;
• Transitional arrangements are put in place to allow sufficient time for the manufacturers and suppliers of the affected ink to comply with the licensing requirements (6 months suggested);
• End-users to be fully exempted and covered by the suggested registration scheme below so they can be monitored, and their usage recorded.
• A consultation takes place with ink manufacturers on the realistic time scale required to reformulate the inks to remove GBL – so they can continue to be used in the current machinery install base without causing financial hardship to end-users, and also thus remove the need long-term for licensing all together.
• A threshold exemption is put in place for GBL and 1,4-BD in product formulations,
below which a licence is not required;
• To address illicit use, a registration scheme is put in place to which companies using the pure substances must submit information e.g. on volumes and other defined parameters. These companies could also be required to validate customer use and undertake appropriate record keeping.
In conclusion, The GPMA understands the decision to legislate against harm from the availability of these substances and their misuse.
However, the impact to business is far greater than was anticipated.
Product mixtures have been dragged into the requirements without due consideration of the risks posed, and there has been a gross underestimate of the time required to obtain a licence, to reformulate products. or to exhaust company stocks.
The GPMA urge therefore urge the government to reconsider the timelines and open a dialogue with Industry and other stakeholders.
The issues raised above are of critical concern to their members and their customers.
The GPMA have therefore asked the government to review the position as a matter of
urgency and is ready to assist in a review process.