The Biobased and Renewable Products Advocacy Group (BRAG) helps members develop and bring to market their innovative biobased and renewable chemical products through insightful policy and regulatory advocacy. BRAG is managed by B&C® Consortia Management, L.L.C., an affiliate of Bergeson & Campbell, P.C.

By Kathleen M. Roberts

Is your company engaged in Class 2 chemistries that are similar to existing Class 2 chemicals but are derived from an innovative bio-source? We are looking for pioneering companies working on new biobased Class 2 chemicals to assist in advancing an important project with the U.S. Environmental Protection Agency (EPA).
 
ISSUE:  While EPA sustainability goals would seemingly include adoption of improved biobased technologies, EPA’s policies under the Toxic Substances Control Act (TSCA) mean that many novel, sustainable technologies are considered “new chemicals” requiring EPA to conduct new chemical assessments.  If these new chemicals are converted to other substances by downstream customers, those substances are likely also new, requiring additional new chemical submissions and assessments.  Each new chemical submission and assessment represents a cost and a commercial delay and each is a barrier to adoption of what may be a promising sustainable technology.  These reviews can and do result in EPA applying risk management conditions on the production and distribution in commerce of the novel, renewable chemicals -- restrictions that may not apply to older chemistries even though they may be functionally identical in performance, hazard, and risk. Ironically, the new chemical may offer a more benign environmental footprint but nonetheless be subject to stricter controls.
 
POTENTIAL SOLUTION:  To address these issues, the Biobased and Renewable Products Advocacy Group (BRAG®) has submitted to EPA, in partnership with the Biotechnology Innovation Organization (BIO), a BRAG member, a White Paper proposing a TSCA Inventory representation and equivalency determinations for renewable and sustainable biobased chemicals. EPA’s initial response to the White Paper has been positive and staff has indicated a willingness to conduct equivalency determinations if submitted. 
 
REQUEST:  BRAG is now seeking companies interested in participating in a pilot project to prepare and submit such requests.  Specifically, we are looking for companies that manufacture or plan to manufacture a Class 2 chemical substance that is functionally equivalent to another Class 2 chemical, but due to existing naming conventions, the two chemicals are not listed as equivalent.  If your company fits this description and you wish to support an effort to alleviate commercial burden for yourself and others in the future, please consider working with BRAG on this important project so we present impactful equivalency cases to EPA.
 
BRAG and Bergeson & Campbell, P.C. (B&C®) are committed to this project.  As such, we will evaluate all candidate chemicals submitted, select what we believe is a good test case for the project, and prepare as a courtesy the necessary submission paperwork and equivalency arguments, in conjunction with the nominating company.
 
Please contact .(JavaScript must be enabled to view this email address) if your company is interested in submitting a nomination.

Tags: BRAG, Biobased

 

Borrowing from William Shakespeare … WHAT’S IN A NAME? That which we call a biobased chemical. By any other name would stand as sustainable. And yet, it is the mere name of the biobased chemical that hinders its ability to go to market!

Did you know that the Toxic Substances Control Act (TSCA) is interpreted and applied in ways that often cause new biobased chemicals and their derivatives to be subject to stringent premarket review by EPA? This review often results in the application of restrictions that are not applicable to older chemical substances already in commerce. This lack of consistency results in regulatory and commercial challenges for new biobased chemical products that hamper commercialization pathways and invite considerable delays to market entry. This oddity of the current EPA naming system results in newer biobased technologies that offer the same, if not greater, benefits than existing chemicals now being commercialized. Any company or organization intending to market biobased products -- whether they come from plants, algae, or industrial waste -- should be aware of this situation and join the effort to create a more sensible regulatory approach.

As a company focused on creating chemistry for a sustainable future, we invite your organization to join BRAG as a member in 2019. BRAG is a group of international and well respected member organizations and companies engaged in the development of biobased or renewable chemical products. BRAG members recognize the importance of advocacy, education, and communication.

BRAG is helping its members understand and comply with the application of TSCA to their products and operations, educating regulatory officials on biobased chemical production and the application of TSCA to these products, and developing strong and compelling advocacy platforms to ensure the robust commercialization and growth of biobased and renewable chemical feedstocks. No other biobased chemical industry consortium focuses on TSCA in this way or on biobased chemical commercialization and associated regulatory inequities. Because BRAG is managed by B&C® Consortia Management, L.L.C. (BCCM), a group that has regulatory compliance advisors, legal counsel, and science policy experts available for consultation and strategy development, we have the legal, technical, and management capacity to identify, develop, and implement successfully strategic plans to modify current EPA approaches or policies.

BRAG is expanding its membership to include more companies that have already been or may be adversely impacted by EPA’s current policies. As the leader in TSCA compliance issues, BRAG provides strength in numbers, which allows for more efficient engagement with EPA on these critical issues for less cost.

For further information, contact Ligia Duarte Botelho at .(JavaScript must be enabled to view this email address).

Tags: BRAG, TSCA

 

By Kathleen M. Roberts 

On June 13, 2018, representatives of the Biobased and Renewable Products Advocacy Group (BRAG®) and representatives of the Biotechnology Innovation Organization (BIO) met with U.S. Environmental Protection Agency (EPA) staff to discuss the two groups’ white paper, “Proposal for a Toxic Substances Control Act (TSCA) Inventory Representation and Equivalency Determinations for Renewable and Sustainable Bio-based Chemicals.”  BRAG and BIO members provided a presentation for EPA staff that outlined the regulatory challenges and market impendence facing the biobased industry related to current naming conventions.  BRAG and BIO look forward to further dialogue with EPA on this crucial issue.


 

By Lauren M. Graham, Ph.D.

On October 24, 2017, Neste, a member of the Biobased and Renewable Products Advocacy Group (BRAG®), announced that it was the only energy company to reach the Leadership-class ranking in three Climate Disclosure Project (CDP) programs.  Neste received an A- ranking in the CDP Climate, CDP Forests, and CDP Water programs.  CDP is a not-for-profit organization that manages a global disclosure system allowing companies, cities, states, and regions to measure and manage their environmental impact.  The CDP Climate program focuses on corporate measures to combat climate risks and take advantage of low-carbon products and services.  According to Pekka Tuovinen, Neste's Senior Advisor for sustainability, “[t]he more efficiently we operate, and the more we can reduce the climate emissions of our own supply chains, the greater will be the climate benefits of the products and solutions we offer.” 
 
Neste is the only energy sector company to transparently disclose its forest footprint as part of the CDP program.  The Leadership-class ranking demonstrates Neste’s commitment to preventing deforestation in its supply chain and requiring similar action from its raw material suppliers.  Neste continues to work on improving the traceability of various kinds of processing residues used as raw materials beyond what is mandated by regulatory requirements.
 
For the first time, Neste participated in the CDP Water program, which requires companies to disclose the measures they implement for responsible water use and water risk management.  According to Mr. Tuovinen, Neste has been carrying out water footprint calculations for its refineries and products since the 1990s.


 

By Lauren M. Graham, Ph.D.

On September 21, 2017, AkzoNobel, a member of the Biobased and Renewable Products Advocacy Group (BRAG®), announced that its Specialty Chemicals business is studying plans to build a world-class plant for its Bermocoll® business, which supplies non-ionic cellulose ethers for the paint and buildings and construction industries.  AkzoNobel uses a unique solvent-free process to manufacture the water soluble and virtually odorless Bermocoll cellulose ethers.  The new facility will increase the production capacity for such cellulosic ethers to help meet growing global demand.  According to Geert Hofman, General Manager at AkzoNobel’s Bermocoll business, “[d]emand for Bermocoll is growing strongly due to the rising consumption of water-based paint and continued growth in the building and construction industry.”  AkzoNobel is considering a number of options for the location of the facility, including the expansion of operations at existing production sites in China, Italy, the Netherlands, and Sweden.


 

By Lauren M. Graham, Ph.D.

On September 13, 2017, Neste, a member of the Biobased and Renewable Products Advocacy Group (BRAG®), announced it is collaborating with Genève Aéroport to make flying more sustainable.  Neste will be providing renewable jet fuel for aircraft operations from Genève Aéroport.  The goal is for one percent of the jet fuel consumed annually at Genève Aéroport to be composed of renewable jet fuel by late 2018.  The collaboration supports Neste’s growth strategy for renewables in applications outside road traffic fuels and Genève Aéroport’s ambitious goals to reduce its greenhouse gas emissions. 


 

By Lauren M. Graham, Ph.D.

On September 5, 2017, AkzoNobel, a member of the Biobased and Renewable Products Advocacy Group (BRAG®), announced that its Specialty Chemicals business signed an application agreement with Itaconix to develop innovative biobased chelates for consumer and industrial detergents and cleaners.  According to Peter Kuijpers, AkzoNobel General Manager of Chelates and Micronutrients, biobased chelates are replacements for the phosphate compounds that are being phased out of consumer and commercial cleaning products due to environmental concerns.  This is the second partnership to emerge since the companies signed a joint development agreement in January to explore opportunities for biobased polymer production.  The first application agreement focused on the development of Itaconix’s proprietary polymers for use in the coatings and construction industries, as reported by the BRAG blog post, AkzoNobel Announces First Biobased Polymer Application Agreement With Itaconix.  All products stemming from the collaboration will be marketed under AkzoNobel’s Dissolvine® brand.


 

By Lauren M. Graham, Ph.D.

On August 14, 2017, Flint Hills Resources, a member of the Biobased and Renewable Products Advocacy Group (BRAG®), announced that construction is underway to install a new, bolt-on technology, known as Maximized Stillage Co-Products™ (MSC), at its ethanol plant in Fairmont, Nebraska.  The MSC technology will be used to convert a portion of the distiller grains, a coproduct of ethanol manufacturing, to a high protein animal and fish feed ingredient, known as NexPro™.  NexPro will be a combination of corn gluten (protein) and spent yeast with close to 50 percent protein and an improved amino acid profile, compared to traditional corn gluten meal.
 
The $50 million project, which involves the addition of a new building and two protein dryers, is expected to last 12 months.  The patented MSC technology was developed by Fluid Quip Process Technologies (FQPT) exclusively for dry mill ethanol plants to separate protein from the solids leftover after ethanol distillation.  Once isolated, the protein is dried into a high-quality meal.


 

By Lauren M. Graham, Ph.D.

On August 24, 2017, Neste, a member of BRAG, announced that its Neste MY Renewable Diesel™ is part of Finavia's climate program.  Initially, the renewable fuel will be used in 20 Helsinki Airport buses, with the goal of expanding its use in the future.  According to Mikko Viinikainen, Vice President of Sustainability & Environment at Finavia, Neste MY Renewable Diesel is an excellent addition to the Finavia’s energy portfolio, which has been working towards carbon-neutral operations by using renewable energy sources; by investing in new, energy-efficient, low-emission solutions; and by compensating for residual emissions.  The renewable fuel can be used in airport buses without any vehicle modifications and is available to all companies operating at the airport.


 

By Lauren M. Graham, Ph.D.

On March 31, 2017, AkzoNobel, a member of BRAG, announced the launch of an online tool that uses e-certification to monitor the biobased content of products.  Companies that sign up to use the online platform will be able to exchange biobased material certificates for everything from base ingredients to finished products.  The online tool eliminates the need for separate, external biobased certifications at various points along the supply chain by allowing companies to transfer the certificates electronically.  According to AkzoNobel, tracking the exact amount of biobased raw materials used throughout the value chain will enable producers and consumers to purchase more sustainable products and move towards a more circular economy.  AkzoNobel partnered with Advanced Biochemical (Thailand) Co., Ltd. (ABT) and EY on the project, which is currently in the pilot phase, to encourage transparency and sustainable chemistry.


 
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