Chemicals in articles and the REACH Regulation

Similar documents
REACH&CLP Coffee: REACH Authorisation: My substance is on Annex XIV what to do next?

Authorisation and Restriction Newsletter

Guidance on the preparation of an Annex XV dossier for the identification of substances of very high concern

EU chemical regulation- REACH Brief Overview and Q&A

Making chemicals safer: Towards 2020

REACH. Scope REGISTRATION. The Current EU Chemicals Policy REACH

REACH 2018 and beyond how the EU legislation is shaping the future of metalworking fluids globally

REACH and Safety Data Sheets

Overview of Key Obligations Under Regulation (EC) No. 1272/2008 on the Classification, Labelling and Packaging of Substances and Mixtures (CLP)

Authorisation and Restriction: Interplay and other Strategic Considerations

Roadmap for SVHC identification and implementation of REACH risk management measures

DISCUSSION NON-PAPER. How to put ideas for cooperation under TTIP into practice a few examples

The Biocidal Products Regulation. Latest developments

REACH Registration Authorization Article 58.2 exemption

EU chemicals management rules and your clients business

Newsletter Volume Two, 2010

Preface. May 26 th 2006

Date. Object: REACH Regulation N 1907/ Dear Supplier,

GHS - GLOBALLY HARMONIZED SYSTEM

Getting Ready for REACH Advanced Solutions for Compliance. John Phyper, CSO & EVP Atrion International Inc.

Chemicals Regulation: A comparison of US and European Approaches. James Searles

ROADMAP. A. Context and problem definition

GHS implementation in EU - The CLP Regulation -

Good Practices Guidance Communication throughout the Supply Chain within the framework of REACH

Chemical Safety Assessment

Articles. REACH Info 6. Requirements for Producers, Importers and Distributors

REACH - Registration and enforcement. Latest trends in REACH and CLP Tokyo 30 March Laura Walin ECHA Guidance and helpdesk

Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Compliance

Compilation of safety data sheets

Guidance for Suppliers of Articles

Brussels, XXX [ ](2015) XXX draft ANNEX 1

Civil Law Product Liability under REACH and CLP Some Basics

Guidance for Suppliers of Articles

Committee for Risk Assessment (RAC) Committee for Socio-economic Analysis (SEAC)

REGULATORY RISK ASSESSMENT OF NANOMATERIALS IN THE EU

GHS CLP ATREAT. The new classification and labelling of hazardous chemicals. Providing a single source for your water treatment chemicals

Multi-Annual Work Programme

ECHA s REACH 2018 Roadmap

New EU pesticide legislation the view of a manufacturer

This document is meant purely as a documentation tool and the institutions do not assume any liability for its contents

REACH: an opportunity for trade unions. Putting knowledge to work in the workplace. Tony Musu Researcher, European Trade Union Institute

REACH and RoHS System Supplier Training

German proposal for the restriction of PAHs in consumer products

EURegulatory Compliance: Challenges and Solutions, EU CLP Regulation Overview.

The importance of substance identity in ensuring a successful registration

Guidance on the preparation of dossiers for harmonised classification and labelling

Guidance on information requirements and chemical safety assessment. Chapter R.2: Framework for generation of information on intrinsic properties

Guidance on waste and recovered substances

View from the OEM REACH and the supply chain

Properties criteria - BETA

Annankatu 18, P.O. Box 400, FI Helsinki, Finland Tel Fax echa.europa.eu

Results of the public consultation on the TOP10 most burdensome legislative acts for SMEs

COMMISSION IMPLEMENTING DECISION. of

1. IDENTIFICATION: PRODUCT IDENTIFIER AND CHEMICAL IDENTITY

REACH requirements for component suppliers and equipment manufacturers

REACH: The role of the UK Competent Authority. Helen McGarry Chemicals Regulation Directorate Redgrave Court, Bootle, HSE

ECHA s approach to SMEs

ECHA s Regulatory Science Strategy

GE Healthcare Approach to REACH

REACH Understanding the Risk Assessment Process

Registration, Evaluation, Authorisation of CHemicals (REACH)

REACH Practical Guide on Safe Use Information for Mixtures under REACH. The Lead Component Identification (LCID) Methodology

Summary of questions submitted to Chemical Watch during and after K-REACH webinar on 14/5/2013

Company A EU Legal Entity Company A Only Representat. Customer. Supply polymer preparation

Annual Report of Enforcement of REACH and CLP 2012 june 25, 2013

Version 2.1 August 2015

The impact of REACH on the aerospace sector - a DU s perspective & response

How To Set An Import Tolerance

REACH-like regulations around the world. Dr. Adriana Jalba Manager, International Chemicals Management (ICM) Cefic

List of Undesirable Substances 2009

Version 1.0 July 11, Developed by: Electronic Enterprise Integration Committee Aerospace Industries Association, Inc.

FINLAND. 1. Provisions in place in the Member States on REACH penalties

OUR CUSTOMERS. Exciting, beautifully designed, excellent quality clothing and homeware that reflects the aspirations and means of our customers

SAFETY DATA SHEET. according to 1907/2006/EC, Article 31. Zenith 2B Machine Rinse Aid (020000, )

How To Comply With The New Toy Directive

GREEN LABEL PLUS. Modulyss GLP1100. The Carpet and Rug Institute, Inc. 15X Predyed Nylon with Bitumen Backing THIS CERTIFIES THAT

Only Representatives Organisation

Antonia Reihlen, Ökopol GmbH

Guidance on information requirements and chemical safety assessment. Part A: Introduction to the Guidance document

Hazard v. Risk in EU Chemicals Regulation

Main concerns resulting from the implementation of REACH

Risk Assessment of nanomaterials from an industry perspective. Jenny Holmqvist

THE BELGIAN NATIONAL REGISTRY OF NANOMATERIALS: WHAT YOU NEED TO KNOW

Guidance on Information Requirements and Chemical Safety Assessment. Chapter R.11: PBT/vPvB assessment

Member States Reporting under REACH art. 117 / CLP art.46

May 10, Office of the United States Trade Representative th Street NW Washington, D.C

German Competent Authority Experiences and Expectations from a Member State s Perspective

Guidance on Information Requirements and Chemical Safety Assessment

Introductie: RIVM Introductie CLP

Conversion template REACH dossier into GPS Safety Summary. 13 June 2013 Version 2: Final draft with comments

December 2-4, 2013 R E A C H C O N F E R E N C E

The Increasing Regulatory World for Candles Global Key Issues. World Candle Congress 2016

Understanding RoHS and REACH: Impacts on your Global Markets

ESA s role & activities to support Cr(VI) replacement

Substance name: N,N-Dimethylacetamide (DMAC) EC number: CAS number: MEMBER STATE COMMITTEE SUPPORT DOCUMENT FOR IDENTIFICATION OF

MEMBER STATE COMMITTEE SUPPORT DOCUMENT FOR IDENTIFICATION OF

How To Understand The European Liability Directive

Chemicals Testing and the New System

Substance name: Hydrazine EC number: CAS number: MEMBER STATE COMMITTEE SUPPORT DOCUMENT FOR IDENTIFICATION OF HYDRAZINE

Transcription:

Chemicals in articles and the REACH Regulation ANEC-ASI CC-BEUC Event on hazardous chemicals in consumer articles Brussels, 04 october 2011 Julien de Cruz Unit D3 Chemicals, Biocides and Nanomaterials

Outline of the presentation The role of REACH in the use of chemicals in articles What s an article Registration obligations Notification obligations Communication of information in the supply chain 0.1% Ways forward

Role of REACH to reduce use chemicals in articles REACH is a substance focussed legislation although it also tackles products through restrictions Also, substances as such can be consumer products (ex: turpentine) So primary aim is to protect Environment and Human Health by controlling the risks in supply chain and reversing the burden of proof of risk on the industry Info gathered through REACH will feed into the product focussed legislation (ie toys, construction, cosmetics)

What is an article under REACH? Substances as defined in REACH can be products (ex: turpentine) Definition of article: An object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. (Article 3(3) of REACH) Guidance on substances in articles (ECHA s website): Is the function of an object determined to greater degree by shape, surface or design article Is the function of an object determined to equal or greater degree by its chemical composition substance/preparation in container/carrier material To help decide in practice indicative criteria. Commission opinion on the issue of buildings and asbestos: Buildings are not articles within the meaning of Article 3(3) of REACH, so long as they remain fixed to the land on which they stand.

Registration of substance in article Registration of a substance covers uses and production of an article is a use Registration of substances intentionally released Substance present above 1 tonne. Agency may require registration for substances: Substance present above 1 tonne The Agency has grounds for suspecting: The substance is released The release presents a risk. The rules above only apply if the substance has not already been registered for that use.

Notification of SiA SVHC: substance of very high concern PBT/vPvB or CMR or similar concern (endocrine disruptor) Placed on the candidate list (ie prioritisation towards Annex XIV) Notification of Substances of Very High Concern if SVHC present above 1 tonne SVHC present above a concentration limit of 0.1% w/w Exposure of the public or the environment during the full life cycle cannot be excluded. Contact details Reg number Name of the substance Description of the use

Communication of information on substances in articles Obligation to provide sufficient information to allow safe use of the article By any supplier of an article to the recipient By any supplier of an article to a consumer upon request For SVHC included in the candidate list Contained in the article in a concentration above 0.1% w/w Including as a minimum the name of the substance. This is one of the shortcomings in REACH as was shown by a study commissioned by the EEB, COM reflecting on better way to raise awareness (The Fight to know) Contact details Reg number Name of the substance Description of the use

Authorisation and importers Authorisation title applies only to articles produced in Europe and not to imported articles Commission is aware that it is imbalance for business Burden for EU producers But in the long run also provides guarantees for consumers that articles produced in the EU do not contain certain substances Consumer awareness will increase Article 69(2) permits ECHA to prepare a restrictions dossier after the sunset date of a substance listed in Annex XIV.

Articles and restrictions - article 68(2) For a substance ( ) in an article which meets the criteria for classification in the hazard classes carcinogenicity, germ cell mutagenicity or reproductive toxicity, category 1A or 1B, and could be used by consumers Commission can propose a restriction which is adopted through comitology (regulatory procedure with scrutiny).

0.1% interpretation: the Commission s line The 0.1% threshold is an element in Notification of SVHC in articles Obligation to provide information on SVHC in articles. Commission Line Objects which at a certain step in their life-cycle meet the definition of article under REACH cease to be individual articles and become components once they are assembled into another article Example: wheel with hub cup The obligations in Article 7(2) and 33 apply only with respect to such assembled article, and not with respect to its individual components.

Ways forward REACH Review : outcome 1 June 2012 Mandated by REACH and will examine several fields Among them gaps (and overlaps) in coverage -> REACH scope review We look how reach relates to other consumer articles - synergies http://ec.europa.eu/environment/chemicals/reach/re view_2012_en.htm ENTR-ENV ENV-REACH-REVIEW@EC.EUROPA.EUREVIEW@EC.EUROPA.EU

Thank you for your attention! Useful links CHEMICALS ON DG ENV http://ec.europa.eu/environment/chemicals/index.htm REACH REVIEW 2012 http://ec.europa.eu/environment/chemicals/reach/review_2012_en.htm Guidance on SiA (ECHA) http://guidance.echa.europa.eu/docs/guidance_document/articles_en.pdf Candidate list of SVHCs http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp