Intertek Experts Explain EU REACH Regulations

The European Union's REACH regulations on the registration, assessment, licensing and limitation of chemicals (Registration, EvaluationandAuthorizationofChemicals) was adopted by the European Union in December 13, 2006 and will be formally implemented in June 1, 2007.

At that time, it will replace the existing directive and regulations on chemicals, such as the classification, packaging and labelling directive of the European Union, which will require registration, evaluation and licensing of all chemicals in the EU market and into the EU market and implement safety monitoring. 40

It is estimated that, because of REACH, the trade between China and the EU will be affected by 140 billion euros. All household appliances, textiles, clothing, footwear, toys, light industry, electronics, automobiles and pharmaceuticals will all be affected and hurt. The trade pattern of China and Europe and even its upstream and downstream industries will face a major reshuffle.

　　中國企業疑惑點一：法規管控范圍

The EU REACH code is known as the "chemical registration, evaluation, licensing and restriction bill". Many domestic enterprises, especially Electromechanical, household appliances, electronics, toys and clothing industries, have come to the conclusion that REACH regulations are related only to petroleum, chemical, pharmaceutical and other industries.

As a matter of fact, REACH regulations require that chemical substances, whether they exist independently or in various products, need authorization or restricted use. If they are substances or products, they need to be registered, if they are to be notified and pmitted.

As a result, up to 5 million kinds of products have been affected, covering almost all products including electromechanical, household appliances, textiles, furniture, toys, cosmetics, daily chemicals and so on.

In addition, according to the provisions of the REACH regulations, the products of 1 tons of chemicals in the chemicals or parts of the European Union are required to be registered, otherwise they are prohibited from entering the EU market.

This is the principle of "no data, no market" in REACH regulations.

At present, most of the chemical products exported to the EU each year exceed 1 tons.

Therefore, the products exported to EU basically belong to the jurisdiction of REACH regulations.

There are about 100 thousand basic chemical substances in the REACH regulations, and about 30 thousand tons of substances in excess of 1 tons / year, which are listed as highly concerned substances, which are commonly referred to as 1500 kinds of toxic and harmful substances.

The previous RoHS regulations only restricted the use of 6 kinds of toxic and harmful substances. Domestic enterprises have already felt a lot of pressure. Now the REACH regulations extend the materials that need to be authorized or restricted to more than 1000 kinds of enterprises, and enterprises will be more difficult to cope with.

　　中國企業疑惑點二：實施時間表

In accordance with the timetable for implementation of the REACH regulations, the REACH regulations will take effect in June 1st this year, and will be pre registered from June 1, 2008 to November 30, 2008.

From December 1, 2008, unregistered or pre registered products will be banned from entering the EU market.

However, many enterprises believe that there is still a period from the actual implementation.

Many companies think that the REACH regulation is a matter of government departments. They expect the government to organize the response, or expect other enterprises to explore the road first.

In fact, the key to the release of substances in materials, products and articles is registration. About 80% of the chemical substances need to be registered only. However, the preparation of registration procedures is very cumbersome. For example, enterprises must first understand the list of chemical substances contained in their products, expose the feasibility analysis, carry out chemical safety assessment and chemical safety report writing, toxicological and ecotoxicological tests, etc. each work can take one or two years.

In addition, for highly concerned substances (SVHC), such as the use of more lead in the electronics industry, we need to notify, pmit information and apply for authorized use.

If the enterprise is lead-free, it will need to submit a plan to clarify the timetable for replacement.

The product will be banned from entering the European Union if it is not authorized or the submitted audit is not approved.

Unlike EU directive RoHS, REACH regulations are mandatory, and products that do not complete registration procedures will be banned from entering the EU market.

At present, it is 2008 August, pre registration has only more than 3 months, but most of the enterprises in China still have not registered preparation work.

Experts worry that if we do not act immediately and miss the registration time, enterprises will either withdraw from the EU market or pay a higher price.

　　中國企業疑惑點三：注冊檢測費用

According to the EU estimates, the basic inspection cost of each chemical substance is about 85 thousand euros, and the cost of testing for each new chemical substance is about 570 thousand euros, plus registration fees, which is very expensive.

If a product involves several hundred or hundreds of chemicals, the cost will be astronomical and no enterprise will be able to bear it.

Some companies worry about the huge cost, feel helpless, and even abandon the idea of the EU market.

In fact, as long as we apply the pre registration procedure set up by the REACH system, we can avoid the high cost problem.

For example, the pre registration of enterprises from June 1, 2008 to December 1, 2008 will become a potential registrar not only to enjoy the registration grace period ranging from 3 to 11 years, but also to participate in the Forum on material information exchange and become one of the sponsors of chemical substances registration.

Through information exchange, avoid repeated tests and reduce the cost of testing.

At the same time, it can share the cost with other enterprises, thus greatly reducing the cost of testing and registration.

There is no high cost for enterprises that actively participate in pre registration.

In this regard, the experts of China's inspection and Quarantine Bureau also reminded enterprises to fully recognize the benefits of pre registration.

At present, the most important task for an enterprise is to communicate with the upstream and downstream customers as soon as possible, analyze the products exported to Europe as early as possible, and understand the total number of products exported to Europe.

Find out whether your products are included in the chemical inventory of REACH regulations, whether registration, notification, authorization, etc., as well as the data and information required to register, are in order to act in line with the REACH law.

If the domestic enterprises do not have a branch in the European Union, they need to find the third party institutions with the sole representative to help themselves to register for REACH. At present, the Intertek group has provided the "sole generation" for the market.