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How To Deal With REACH Regulations In Chemical Fiber Enterprises

2008/8/28 15:31:00 22

China's chemical fiber products exported to the EU include synthetic fiber raw materials, man-made fiber materials, natural fiber synthetic fibers, raw materials, chemical fiber staple, chemical fiber filament, chemical fiber staple textiles, chemical fiber filament textiles, chemical fiber knitwear and chemical fiber clothing.

The definition of chemical fiber products in REACH regulations is rather complicated.

There are products belonging to the category of "material" or "matching products", such as synthetic fiber raw materials, man-made fiber raw materials, natural fibers, synthetic fibers, some raw materials (acrylonitrile, p-xylene, polyester chips, etc.). There are also products belonging to the category of "goods", such as chemical fiber staple textiles, chemical fiber filament textiles and chemical fiber knitwear, etc. there are also products between the "fuzzy" boundary of "material" and "goods", such as chemical fiber staple, etc. such products need to be analyzed by professionals for specific cases.

According to the REACH regulations, China's chemical fiber enterprises need to appoint a reliable and reliable "sole representative" to fulfill the relevant responsibilities of the EU REACH regulations.

The responsibilities of chemical fiber products in the REACH regulations include (pre) registration, information pfer, authorization, notification and restriction in the supply chain.

The general steps for chemical fiber enterprises to deal with EU REACH regulations are as follows:

1. list enterprises' trade products to the EU;

2. according to the registration guidelines for REACH regulations, the guide for the demand for substances in materials, and the guide to naming and identifying substances (the electronic version can be downloaded from the website of the China Inspection and quarantine REACH Solution Center website www.reach.gov.cn), it distinguishes the "goods" and "substances" from the trade products of the EU, and calculates the tonnage of substances exported to the EU (for the products which are relatively difficult to identify, it can seek professional agency's help).

3. list all the goods list that exports more than or equal to 1 tons per year.

4. according to the applicable scope of the REACH regulations (the electronic version can be downloaded from the REACH website of the China Inspection and Quarantine Center), list all the material lists that need to fulfill the obligations of REACH; (REACH)

5. collect information (REACH, CAS, etc.) that is required to fulfill the obligations of the law.

6. search for the "sole agent" who is reliable and reliable, and conduct REACH (pre) registration of substances.

In view of the particularity of chemical fiber products, some issues in the process of dealing with EU REACH regulations are especially worth registering with chemical fiber enterprises.

The first is the definition of products in the REACH regulations.

In the European Union's REACH regulations, according to the function of the product, its shape, surface and design are more important than its chemical components, which are divided into "material / product" and "goods".

In the REACH code, substances need to be registered (pre) for their chemical components, and goods only need to register (pre) substances for their intended release.

It is particularly reminding that in the process of processing raw materials (materials) into final products (goods), the determination of the limits of "material" and "goods" requires analysis of specific cases.

Secondly, some of the chemical fiber products are natural products or substances that are listed in Annex IV of the REACH code, that is, products are produced by natural products and substances that have the smallest risk because they know enough information, such as mulberry silk, non combed cotton, cotton short pile pulp and so on.

According to REACH regulation sixth (7), these substances are exempt from registration.

It should be noted that in the REACH regulations, the "natural generated substances" have their strict definition. Enterprises need strict control to determine whether their products belong to "natural generated substances". The EU is conducting a further assessment of the substances in Annex IV. The latest news is that carbon and graphite have been removed from annex IV, and enterprises need to pay attention to changes in Annex IV.

In addition, some of the chemical fiber products belong to the category of "goods".

According to the latest "guide to material needs in goods" issued by the European Chemicals Bureau, producers of "goods" need to know all the chemicals contained in their products to determine whether their products need to fulfill the obligation of information pmission, notification and restriction in the supply chain.

Some of the raw materials in chemical fiber products are purchased from other suppliers (such as pigments, etc.).

This needs to straighten out the information pmission in the supply chain, so that suppliers can provide enough information to enable enterprises to determine whether their products comply with the requirements of REACH regulations.

It will take a long time to establish a product management system conforming to the REACH regulations and straighten out the information pmission in the supply chain, so enterprises need to start preparations as early as possible.

Related tips in June 18th this year, the European Chemical Industry Council (CEFIC) issued second REACH guide documents, specifically guiding the formation of REACH SIEF (the guide electronic version can be downloaded from the www.reach.gov.cn website of the China Inspection and quarantine REACH Solution Center).

The EU REACH regulation has officially started the registration process in June 1, 2008.

As of June 13, 2008, 7360 substances were successfully submitted for pre registration.

China's chemical fiber enterprises must firmly grasp the pre registration period before December 1st, and do a good job in dealing with REACH regulations.