Enterprises Pay Attention To REACH Regulations And Stabilize EU Export Path

In the analysis, the South German group experts said: REACH is a more complicated law. If the enterprises exporting to the EU fail to meet the requirements of the regulation, they may have serious consequences.

However, manufacturers and importers should follow the guidance of experts and understand the REACH regulations step by step, so it will be much easier for enterprises to conform to the REACH plan / method / method.

In November 2009, a European Union rapid alert system (RAPEX) set up for non food products reported a case.

A group of Chinese made underpants were found to contain higher content of aminobenzobenzene contained in the new EU chemical regulations (REACH).

As a result, the importer automatically recalled the products from the consumers and put them off the market in Germany and Austria.

Due to the high cost performance of azo dyes and pigments, they are often used to dye natural and artificial materials.

However, aromatic amines dispersed from these dyes and pigments can cause cancer.

P-aminobenzene is a harmful chemical released by these dyes and pigments.

This product was recalled more than this incident.

The report shows that many European retailers, importers and their upstream suppliers do not know much about REACH regulations and their obligations.

The above case illustrates that ignoring REACH regulations will cause enterprises to suffer losses and damage brands.

The REACH regulations replaced and revised the 40 EU chemicals directive, creating a single and harmonious framework for the management of chemicals in the EU.

In order to protect human health and environment from the negative effects of chemicals, REACH controls quality control of consumer goods such as fabrics, clothing, shoes and other textiles.

This regulation is applied to 27 European Union countries and Iceland, Liechtenstein and Norway. Each country has issued a series of punishment measures to meet the requirements of violation of the REACH directive (see the REACH regulations below).

The punishment measures vary from country to country. Some countries not only impose fines on them, but also face serious jail conditions.

Apart from punishing measures, once the news is public, the brand will also be damaged.

Section second of section REACH of regulation thirty-third shows that consumers have the right to ask suppliers to provide relevant information about harmful chemicals contained in their products.

This right is widely used by non-governmental organizations, and the results are also given to outside communiques.

REACH puts the responsibility of chemical safety on the manufacturers and importers of the European Union.

If you are a manufacturer or importer of the European Union, the meaning of the REACH regulation is that if you do not comply with the requirements set forth in the REACH regulations, you need to bear legal liability, not your upstream suppliers from non EU countries.

The REACH regulation states that REACH regulations represent the registration, evaluation, restriction and authorization of chemicals. This is the four key step of this directive, and the whole process is supervised by ECHA.

In the REACH directive, chemicals refer to a substance, and all products can be roughly divided into three categories according to their composition: substance, mixture and substance.

If the product is pure chemicals, it is called substance.

Calcium chloride, which is often used by writers as desiccating agent, is an example.

If the product is made up of two or more substances, it is called a mixture.

For example, washing powder is a mixture of various chemicals, including surfactants, fluorescent whitening agents and aromatics.

Most textile products are classified into third categories, that is, goods.

For example, a shirt is an object.

As REACH says, objects refer to objects that are acquired in a specific shape, appearance, or design during manufacture, and these characteristics determine their functions more than their chemical constituents.

Packaging material is an item that can not be ignored.

Under the REACH code, each packaging material is a separate item.

Therefore, packaging materials must also comply with the requirements for conformity.

Under the category of goods, there is a branch which is intended to release substances.

For example, a piece of microencapsulated antimicrobial agent is released under the normal use of the antibacterial agent, which is added to the fabric, thereby adding value to the product.

In terms of deliberate release, this function is only an additional function rather than a main function.

Thus, to understand the obligations stipulated in the REACH regulations, we must first understand the meaning of substances, mixtures, objects and intended release.

For textile products, the categories of products that need to be registered are only those that are intended to release substances.

The responsibility of the EU importers is to ensure that all registered imports are registered in a timely manner.

Registration can be done either by the importer itself or by any upstream supplier in the supply chain.

Since registration is a costly and lengthy process, the details of concern are not discussed in this article.

If you have substances that are intended to release substances, and want to confirm whether there is a need for registration, we suggest that you contact the REACH expert of the professional certification and testing agency to ensure your responsibility and how to complete the registration in the most economic circumstances.

The evaluation is to check the data submitted by the registration office (for example, the completeness of the relevant registration documents and the evaluation of the chemical test cases).

The process of evaluation is undertaken by ECHA or member states of the European Union.

For manufacturers, they do not have to bear any obligation to evaluate.

The two part of the restriction and authorization discussed below is the REACH control mechanism for hazardous chemicals.

Restricted substances indicate that for the textile industry, azo dyes, ortho benzene two formates, nickel and so on are all familiar restricted substances.

These chemicals are widely used, such as improving the appearance and comfort of clothes.

However, these ingredients are proved to be harmful to the environment and human health.

For example, pentachlorophenol (PCP) can sometimes be used as a preservative or preservative in fabric, but it is restricted because of its carcinogenic risk.

Before the REACH regulations came out, restricted substances in consumer goods were basically included in the marketing and use directive (76/769/EEC directive).

This directive was implemented in 1976.

Over the years, with the increasing knowledge of chemical hazards, new restrictions have been added to the directive.

Eventually, a total of 57 chemicals involving hundreds of substances were included in the directive.

Since June 1, 2009, the directive on marketing and use is no longer in use, but the requirement under this directive is included in Appendix seventeen of the REACH code.

SVHC and manufacturers' obligations indicate that the REACH method introduces a new type of chemical components, that is, highly concerned substances.

High attention substances refer to chemicals that cause serious harm to human health and the environment.

The purpose of empowerment is to control the risks posed by gradually replacing the highly concerned substances with safer substances or technologies.

In the two stages of the authorization process, two lists require different obligations.

The list of candidates is required to fulfill two obligations: 1, communicate with supply chain vendors, 2, notify ECHA.

The authorization list requires the right to use the substances listed.

(1) communicate with supply chain manufacturers: if goods contain high quality substances in the list of candidates, and the ratio is higher than 0.1%, or when consumers ask for high interest substances in goods, you need to supply the name of the highly concerned substance with suppliers or consumers, and submit all relevant safety instructions.

For consumer enquiries, these information must be provided within 45 days.

The first case can be illustrated by an example.

Assuming that a batch of buttons is imported, these buttons contain a high concern substance on the list of candidates, and the proportion of the ingredients in the buttons reaches 0.5%, so the supplier must inform the buyers of the products (for example, the importers or shirts manufacturers of these buttons imported from EU), because the ingredients of the high attention matter exceed the limit of 0.1% of the regulations.

However, if these buttons are part of some imported shirts, the proportion of the highly concerned substances in the buttons will be calculated in proportion to the overall weight of the shirt.

If the material composition is less than 0.1% in a shirt, there is no need for information communication.

So far, seven countries do not agree with the definition of the 0.1% weight ratio. The seven countries are Austria, Belgium, Denmark, Germany, France, Sweden and Norway.

If imported goods are to be sold in these countries, we recommend that we first understand clearly and clearly the definition of "0.1% weight ratio" in these countries. If there is any doubt, the REACH help desk of the countries concerned can provide more information.

It must be noted that once the matter of high concern is included in the list of candidates, the obligations related to it will take effect immediately.

These obligations have been implemented in October 28, 2008 (the first announcement of a list of 15 highly interested substances).

After that, ECHA added 14 kinds in January 13, 2010, and added acrylamide to the list of candidates in March 30, 2010. The current list of candidates includes 30 kinds of highly concerned substances.

(2) to inform ECHA that when the weight ratio of highly concerned substances in an article is above 0.1%, this obligation must be carried out every year when each manufacturer or importer uses the overall weight of this high concern substance greater than one ton.

The Notice applies to 2011 June 1st.

A manufacturer or importer needs to pay attention to the change, because a new candidate list of SVHC meets the standard notice must be notified to the humane Executive Committee to be listed in half a year.

The difference is the obligation to communicate, which also applies to exemption obligations under any circumstances. Therefore, it is recommended that you seek expert advice if you feel that you can apply for notification.

Notification obligations will take effect in June 1, 2011.

Manufacturers or importers must pay attention to the development of the list of candidates, because when a new highly concerned substance is included in the list of candidates, if it meets all the requirements of the notification obligation, the notification must be given to ECHA within six months.

The obligation to communicate with suppliers of supply chain is different. Communication is applicable in any case, while notification may be exempt in some cases.

So if you encounter problems related to the notification, you can consult the experts.

(3) authorization: once a highly concerned substance is included in Appendix fourteen (authorization list), unless the authority has been authorized, the matter of high concern will be put on the market or used in production after the EU deadline (the "sunset" date).

However, it is easy to confuse importers with the fact that authorization is only applicable to imported substances and mixtures, but not to goods.

This is a must for importers.

Although the "authorization" does not apply to imported goods, some brands may choose to dispose of all the highly concerned substances in all Appendix 14 so that their imports will be consistent with the safety level of the products manufactured by the European Union.

Therefore, for commercial interests, non EU manufacturers should also understand the content of appendix fourteen.