Analysis of the Final Report on the Third REACH-EN-FORCE Project: Advice on REACH Supply Chain Compliance

Recently, ECHA published the final report of the third REACH-EN-FORCE (REF) Project. REF3 covered 28 countries, with 1,169 companies and 5,746 substances inspected during 2013-2014. Detailed investigations during phase 2 of the project revealed that only representatives (OR) and importers are more at risk of non-compliance than manufacturers of substances. As is described by ECHA, “The project was coordinated by ECHA’s Enforcement Forum and implemented in close cooperation with national customs authorities.” A total of 104 ORs were inspected and a third of them (32 %) did not comply with their specific OR information duties as described by Article 8 of REACH. The investigation revealed that the supply chain data (e.g. tonnage coverage) collected from importing downstream users was regularly inconsistent with the information provided by the OR. “The flow of information in the supply chain between only representatives and importing downstream users was poor. It was often difficult to…

Dec. 22nd, 2015

ECHA Asks Registrants to Show their Considerations of Alternative Methods before Consulting on Testing Proposals

To protect the welfare of animals, ECHA has started requesting additional information from registrants who submit new testing proposals for vertebrate animal tests as an approach to ensure that testing on animals is only done as a last resort. According to the news released by ECHA on November 2, ECHA has sent the first requests to registrants asking them to inform ECHA of their considerations of alternative methods to support their testing proposals involving vertebrate animals. This affects testing proposals made since 11 September 2015. ECHA will publish the information received concerning considerations of alternative methods together with the testing proposals on ECHA’s testing proposals consultation web page. In this way, third parties can get access to such information and consider more comprehensively when deciding whether to submit relevant information about the substance from alternative methods that may avoid the test. More information will be taken into consideration by registrants…

Dec. 10th, 2015

ECHA Helps Potential Registrants Get Prepared for the REACH2018 Deadline

As the last deadline of May 31, 2018 for REACH registration comes close, the European Chemicals Agency (ECHA) has taken several steps to facilitate joint registration before 2018. On the one hand, ECHA provides materials online to support registrants in their efforts for REACH compliance. On the other hand, much improvement has been made to the IT tools for better and efficient delivery of data. Materials are being published by ECHA to help for the two phases of the REACH2018 Roadmap this year: phase 1 ‘Know your portfolio’ was launched in June and the launch of phase 2 ‘Find your co-registrants’ took place in November. ECHA will continue to create new support web pages next year and roll out phases 3 to 6 of the Roadmap. Technically speaking, a “new generation” of IT tools to support REACH registration will be available next summer: IUCLID for creating dossiers; REACH-IT for submitting…

Dec. 10th, 2015

How to Comply with REACH for the Flavor and Fragrance Industry

The Registration, Evaluation, Authorisation and Restriction of Chemicals (‘REACH’) Regulation (EC) No 1907/2006 came into force on 1 Jun 2007. The central principle of this regulation is to integrate approximately 40 pieces of existing chemical legislations. It has significant influence all over the world. Flavors and Fragrances are widely used in industry, and the manufacture, import and uses of them in EU are regulated under REACH accordingly. REACH24H Consulting Group has helped hundreds of Flavors and Fragrances enterprises comply with REACH since it came into force. Some of them appointed us as OR to submit the registration acting as the Lead Registrant (LR). With the approaching registration deadline of 2018, more and more Flavors and Fragrances enterprises need to prepare for the registration the sooner the better. We summarize the previous experience in registration of Flavors and Fragrances to help more enterprises better comply with REACH. 1.   Requirements for Flavors…

Nov. 12th, 2015

Updates on Restrictions of Bisphenol A, DecaBDE and PFOA and Two Opinions for Authorisation

According to the news released by ECHA on 15 September, 2015, SEAC has concluded on restriction proposals of three substances including Bisphenol A, DecaBDE and PFOA and formed two opinions for authorization concerning the use of trichloroethylene and lead chromate under specified circumstances. Public Consultation on the Proposed Restriction of Bisphenol A (4,4′-isopropylidenediphenol, BPA) SEAC agreed its draft opinion on the French proposal to restrict the placing on the market of thermal paper containing Bisphenol A (e.g. point of sale tickets and receipts). SEAC didn’t think that the proposed restriction would greatly affect the economic efficiency but rather may have favorable distributional and affordability considerations. RAC also pointed out in June that the risk for workers (e.g. cashiers) handling thermal paper is not adequately controlled, and supported the French proposal to restrict the placing on the market of thermal paper containing Bisphenol A. The 60-day public consultation on the SEAC…

Sep. 17th, 2015

Seven Proposed SVHC Are Soliciting Public Comments

On August 31, 2015, seven substances proposed by ECHA, Germany, Austria and Sweden to be identified as Substances of Very High Concern (SVHC) have been approved and are soliciting public comments. The deadline for commenting is October 15, 2015. These 7 substances are proposed as SVHC because they can be carcinogenic, vPvB, PBT, toxic for reproduction and have probable serious effects to human health. If no objections arise from the public, the number of SVHC included in the Candidate List will increase from 163 to 170 by the end of this year. Here below is the detailed information on the seven substances. Name EC NO. CAS No. Proposing Authority Reason for Proposing 1,3-propanesultone 214-317-9 1120-71-4 ECHA Carcinogenic (Article 57 a) 2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327) 223-383-8 3864-99-1 Germany vPvB (Article 57 e) 2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350) 253-037-1 36437-37-3 Germany vPvB (Article 57 e) Dicyclohexyl phthalate 201-545-9 84-61-7 Sweden Toxic for reproduction (Article 57 c); Equivalent…

Sep. 09th, 2015

First list of existing chemical substances subject to K-REACH registration is officially published

First list of existing chemical substances subject to K-REACH registration is officially published today. 510 existing chemical substances are listed, most of which are not very different from draft version published in October, 2014.

Jul. 03rd, 2015

First list of existing chemical substances subject to K-REACH registration is officially published

First list of existing chemical substances subject to K-REACH registration is officially published today. 510 existing chemical substances are listed, most of which are not very different from draft version published in October, 2014.

Jul. 03rd, 2015

Two New SVHCs added to the Candidate List

On 15 June 2015, ECHA added two new substances of very high concern (SVHCs) to the Candidate List. The Candidate List now contains 163 substances, and 31 of them have subsequently been included in the Authorisation List. The detailed information of these two substances are as follow: Substance Name EC Number CAS Number SVHC Property 1,2-benzenedicarboxylic acid, di-C6-10-alkyl esters； 1,2-benzenedicarboxylic acid, mixed decyl and hexyl and octyl diesters with ≥ 0.3% of dihexyl phthalate (EC No. 201-559-5) 271-094-0 272-013-1 68515-51-5 68648-93-1 Toxic for reproduction karanal 5-sec-butyl-2-(2,4-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [1], 5-sec-butyl-2-(4,6-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [2] [covering any of the individual stereoisomers of [1] and [2] or any combination thereof] / / vPvB What is Candidate List? “The Candidate List is a list of substances that may have serious effects on human health or the environment. Substances on the Candidate List are also known as “substances of very high concern”. The aim of publishing such a list…

Jun. 16th, 2015

The Administrative Charge for Incorrect Declaration of SME Company Size has reduced

On 12 June 2015, ECHA’s Management Board has reduced the administrative charge for registrants that qualify for the EU definition of a micro, small or medium-sized (‘SME’) company, and came into force on 4 June 2015. From now, incorrect declaration of company size registrants can pay 2.5 times the financial gain (the difference between reduced SME fees incorrectly paid and the fees applicable to the correct company size category). As we all know, SME companies can benefit from reduced fees under the REACH regulations. The reductions for micro, small and medium-sized enterprises are 10%, 40%, and 70% respectively. If registrants that fail to demonstrate their entitlement to the claimed reduced SME fees, are required to pay the correct fee as well as an administrative charge. The revised scales of the administrative charge are presented in the following table: Size of company Administrative charge (€) Large (non-SME) If a large (non-SME)…

Jun. 15th, 2015
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