- Practical Guide -
Page 99 of 153
BADGE/BFDGE/NOGE - Part 2
List of pertinent Directives
Use of certain epoxy derivatives
(BADGE, BFDGE, NOGE)
Nota bene. The Directive 2002/16/EC has replaced the previous one 2001/61/EC [A24],
which is repealed. The comment refers to the new Directive.
Field of application (Art. 1)
This Directive shall apply to the following materials and articles:
Materials and articles made of any type of plastics
Materials and articles covered by surface coatings
manufactured with or containing one or more of the following substances:
2,2-Bis(4-hydroxyphenyl)propane bis(2,3-epoxypropyl) ether hereinafter called "BADGE", and some of its
Bis(-hydroxyphenyl)methane bis(2,3-epoxypropyl)ethers hereinafter called "BFDGE", and some of their
Other Novolac glycidyl ethers hereinafter called "NOGEs", and some of their derivatives.
This Directive shall not apply to containers or storage tanks having a capacity greater than 10 000 litres or to pipelines
belonging to or connected with them, covered by special coatings called "heavy-duty coatings"
The reasons for the exclusion of large containers are explained in (new) recital nr. 10. The
definition of the capacity of 10,000 l was proposed by industry and accepted by the
legislator. The migration of BADGE and particularly NOGE, which is largely used as
starting substance, is not significant and therefore it was agreed that it was not necessary
to establish a migration limit, which would be difficult to enforce.
Aim of the Directive (Art. 2, 3 and 4)
Articles 2-4 establish restrictions to the use of BADGE, BFDGE, NOGE and derivatives
having at least one epoxy or chlorohydrin group. The SML for BADGE and the
corresponding derivatives was established on the basis of the SCF opinion. The SML for
BFDGE and the corresponding derivatives was based on the similarity of its toxicological
profile with BADGE. The restriction for NOGE was expressed as a maximum quantity in the