How to Protect Your EU REACH Registration Number?

The registration number is a necessary condition for enterprises to enter the EU market, and it’s very difficult to distinguish whether the registration number is true or not in the industry sometimes. Generally, importers with strong compliance awareness will actively contact their only representative (OR) to confirm the authenticity of the REACH document. REACH24H also received many inquiries from importers, and in the process of authenticity on registration number, we deed identified a number of “forged” documents. Among the most common compliance documents, Confirmation Letter of REACH Registration, Submission Report, and REACH Compliance Import Certificate are the most frequently forged. Even importers have repeatedly received tampered REACH documents. REACH24H’s RSCC system is a platform designed to help enterprises meet the requirements of REACH regulations. Its principles  can be summarized as follows: OR does not recognize the information confirmed by non-trade parties; OR will not be responsible for the records generated…

Feb. 29th, 2020

MEM Officially Issues the Guideline for Hazchem Enterprises on Emergency Preparations for Production Safety Accidents

Takehome: The Guideline introduces the fourteen essential factors in the emergency preparation and provides a worksheet containing the specifics of these factors as annex for reference. The emergency management administrations shall strengthen the publicity and education of the Guideline and the local administrations shall be responsible for the supervision, inspection, and instruction. On December 26th, 2019, China’s Ministry of Emergency Management (MEM) issued a Notice [1] to publish the Guideline for Hazchem Enterprises on Emergency Preparations for Production Safety Accidents. Major accidents involving hazardous chemicals have been a big problem for China and have garnered huge attention both domestically and overseas. To combat and prevent these accidents, China has introduced a series of regulations and standards for the safe production of hazardous chemicals. (ChemLinked News Ⅰ [2], Ⅱ [3]) The Guideline was formulated to further improve the ability of enterprises to effectively prevent and respond to hazardous chemical accidents. The…

Jan. 10th, 2020

Japan MHLW Proposes Addition of Six Poisonous or Deleterious Chemical Substances

Takehome: Japan MHLW proposed to designate six more poisonous or deleterious substances. On December 5, 2019, the Japanese Ministry of Health, Labor and Welfare (MHLW) held an internal meeting. Based on preliminary findings it was proposed that six substances could be designated as poisonous or deleterious substances. The details of the six substances are shown in the table below. Substance Name CAS No. Toxicity Test Item(s) Result Dibutyltin Dichloride 683-18-1 Acute toxicity (inhalation) Poisonous substance 3-Amino-1-propanol 156-87-6 Skin corrosion/ Serious eye damage Deleterious substance Triacetoxyethylsilane 17689-77-9 Skin corrosion Deleterious substance 9-Octadecen-1-amine, (9Z)- 112-90-3 Skin corrosion Deleterious substance 1-Chloro-4-nitrobenzene 100-00-5 Acute toxicity (oral)/ Acute toxicity (dermal) Deleterious substance 2,4-Dichlorophenol 120-83-2 Acute toxicity (dermal), skin corrosion, and serious eye damage Deleterious substance Later on December 20, the MHLW issued a notice [1] to chemical industry associations in the country, with a view to soliciting applications for a review of the finding mentioned…

Dec. 27th, 2019

EU Says NO to the Import of Toys Containing Lead and Phenol

In order to ensure the protection of children against risks caused by chemical substances in toys, on October 28, 2018, an amendment to EU Directive 2017/738 on lead limits in Appendix II of the Toy Safety Directive 2009/48/EC was officially approved. In the table under point 13 of part III of Annex II to Directive 2009/48/EC, the entry for lead has been replaced by the following: Element Lead In dry, brittle, powder-like or pliable toy material (mg/kg) In liquid or sticky toy material (mg/kg) In scraped-off toy material (mg/kg) Under original Directive 13.5 3.4 160 Under amended Directive EU 2017/738 2.0 0.5 23 In addition to this latest amendment, Directive 2009/48/EC on the safety of toys had already issued a limitation in the values of phenol allowed in toy materials back in May 2017. According to this amendment, values of phenol in toys intended for children under 36 months and…

Oct. 29th, 2018

ECHA offers speedier processing times for REACH dossiers

The European Chemicals Agency (ECHA) has just released a notification for companies that are interested in submitting their REACH dossier in the face of its current May 31st 2018 deadline. Companies that submit their dossiers before the end of March will receive ECHA’s decision on the registration within three weeks of filing. The agency is expecting high levels of submissions in the months of April and May, thus companies filing REACH dossiers over these later months may need to wait up to three months to receive ECHA’s decision. In order for a dossier to be submitted, it must first be uploaded in REACH-IT, and then it must successfully pass completeness check. As the completeness check carried out by ECHA staff not follow a prescribed time, REACH24H strongly recommends its clients to submit their REACH dossiers if possible before March 31st. This should provide sufficient time to receive a registration number…

Mar. 16th, 2018

The U.S TSCA Inventory “Reset” Rule Comes into Effect with A Reporting Period of Only 180 Days

The U.S. Toxic Substances Control Act (TSCA) final rule on the TSCA Inventory Notification (Active-Inactive) Requirements was published in the Federal Register on August 11, 2017, becoming effective as of the same date. This is the third TSCA framework rule under the 2016 TSCA Reform Act, which requires EPA to designate chemical substances on the TSCA Chemical Substance Inventory as either “active” or “inactive” in U.S. commerce. To accomplish that, EPA finalized the rule requiring industry reporting of chemicals manufactured, imported or processed in the U.S. over the past 10 years. This reporting will be used to identify which chemical substances on the TSCA Inventory are “active” in U.S. commerce and will help inform the prioritization of chemicals for risk evaluation. The rule on the TSCA Inventory Notification Requirements includes the following provisions: 1、A Retrospective Reporting with the EPA for chemical substances on the TSCA Inventory that were manufactured (or…

Sep. 14th, 2017

List of K-REACH Lead Registrants Published for 316 PECs

News Source: ChemLinked Takehome: 8 PECs subject to K-REACH joint registration finished LR (lead registrants) election in Apr 2017. So far LR election has been completed for 316 PECs and there are still 194 PECs requiring LR election. Updated on 28 Apr 2017, 316 priority existing chemical substances (PECs) have finished LR election, of which 8 PECs newly completed the election process. The details of the 8 PECs are specified as below. CAS No. Chemical Name LR Election Name of LR 74-94-2 Dimethylamine borane ; DMAB Apr 4, 2017 주식회사 켐토피아 124-63-0 Methanesulfonyl chloride Apr 10, 2017 주식회사 우진화인켐 79-04-9 Chloroacetyl chloride Apr 13, 2017 주식회사 에스피상사 50-00-0 Formaldehyde ; Formalin Apr 13, 2017 삼양화학실업㈜ 122-19-0 Benzyldimethyl-octadecyl ammonium chloride Apr 19, 2017 신원통상 13463-41-7 Zinc pyrithione Apr 20, 2017 ㈜켐토피아 14915-37-8 2-Pyridinethiol-1-oxide, copper salt Apr 24, 2017 ㈜켐토피아 25154-52-3 Nonylphenol Apr 25, 2017 ㈜켐토피아 The LR election results were published with…

May. 05th, 2017

Lautenberg Act Finally Signed by President Obama: a Milestone in TSCA Modernization

On June 22, 2016, President Obama signed the historic Frank R. Lautenberg Chemical Safety for the 21st Century Act, which amends the 40-year-old Toxic Substance Control Act (TSCA), the primary chemicals management law in the Unites States of America. According to the Environmental Protection Agency (EPA), the new law, which received bipartisan support in both the U.S. House of Representatives and the Senate, includes much needed improvements such as: Mandatory requirement for EPA to evaluate existing chemicals with clear and enforceable deadlines; New risk-based safety standard; Increased public transparency for chemical information; and Consistent source of funding for EPA to carry out the responsibilities under the new law. It is the first overhaul to the nation’s chemical laws in nearly 40 years, a milestone in the history of environmental legislation. Companies manufacturing or importing chemical substances in the U.S. shall pay attention to the new amendments and make compliance strategies accordingly…

Jul. 12th, 2016

ECHA to Review Completeness of over 800 Registrations

According to the news released on April 8, 2016 by ECHA, over 8000 REACH registration dossiers in total will be reopened for completeness checks to uphold the “one substance, one registration” principle. The first set will be the 118 charcoal dossiers, following the decision of last month’s Board of Appeal ruling. ECHA will also recheck all dossiers which may be in breach of the joint registration principle of REACH. This means that approximately 700 individual registrations submitted under the REACH Regulation will be reopened, representing 1.5% of all registrations. At the same time, ECHA will recheck the completeness of the dossiers in its database with regard to the information requirements to verify that the information provided is meaningful. It is highly suggested that companies registered individually keep close contact with their OR. ECHA suggests that companies check the relevance of the information that they have submitted and make sure that…

Apr. 13th, 2016

ECHA Reminds Companies to Check the Credibility of the Lead Registrant before Accepting False Invitations

It is reported in the news released by ECHA on 22 February that some companies falsely claimed to be lead registrants (LR) for certain substances. Here REACH24H Consulting Group would like to kindly suggest that companies give a second thought to the credibility of the claimed LR. According to the core principle of “one substance, one registration” of EU REACH, the election and determination of LR must follow specific procedures. The claimed LR identity can be problematic in that the nomination might has not been agreed between the co-registrants, another lead registrant could have been selected or even a joint registration has been already submitted. If you are approached by such a company, you should not accept their offer to prepare a joint registration, but to look for the real lead and other registrants of your substance. For the invitation from a claimed LR, be it true or false, it…

Feb. 26th, 2016
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