China EU Trade Pattern Is Facing A Major Reshuffle. The Cost Of Export Registration To Europe Will Increase By 5%.

Mr. REACH, who runs a textile enterprise in Dongguan, suddenly sent a fax form to his client last month, insisting that he fill in the information about a new term, "REACH", or else he could not continue to cooperate.

Mr. Yuan, who had never touched this term, was baffled, so he turned to help the expert REACH.

In June 1st this year, following the successive implementation of the two major environmental directives of RoHS and W EEE, the European Union has another very stringent environmental directive, the REACH regulation (the registration, evaluation, authorization and restriction system of chemicals), which will take effect from June 1st next year.

After the implementation of the regulation, the trade of household appliances, textiles, clothing, footwear, toys, light industry, electronics, automobiles, pharmaceuticals and so on will be affected. The whole trade pattern of China and Europe and even its upstream and downstream industries will be faced with a major reshuffle.

However, in the REACH symposium held at Pazhou Museum of Guangzhou Trade Fair recently, the reporter's current situation is very worrying: the problems raised by the enterprises directly exposed that the vast majority of SMEs in China still have a superficial understanding of REACH, and most of them have a wait-and-see attitude.

The total cost of exporting products to the EU is increased by 5%. Xie Zhaoming, the keynote speaker of the Symposium and SGS, a researcher at the mainland China and Hongkong research and development department, said that REACH controls all chemicals in the EU market. Whether it is in itself or in the products or articles, it will be faced with a series of problems such as registration, assessment, testing, authorization and restriction in the manufacturing, import, marketing or use of the EU, and the cost involved may be as high as several hundred thousand euros.

The increased cost brought by the REACH regulations will push some small and medium-sized enterprises with competitive strength into a serious situation.

It is estimated that the total certification fee of each export product is as high as 2 million yuan to 3 million yuan RMB. The basic inspection fee will only cost about 1 million yuan, and the total cost of product registration in China will increase by 5%.

In addition, the EU's requirements for chemical products testing and testing are quite high. Enterprises need to spend a lot of energy to collect relevant data and information, and the difficulty and cost of export enterprises will be increased step by step.

Yan Bangsong, vice president of the China Minmetals Import and Export Chamber of Commerce, pointed out in an interview with reporters that the EU is the largest export market for China's five minerals and chemical products. In the first 8 months of this year, the export volume of China's Minmetals chemicals totaled US $156 billion 530 million, of which the export to the EU was US $30 billion 240 million, an increase of 60%.

From this perspective, whether domestic enterprises can cope with REACH will have a profound impact on China's exports to the EU.

Small and medium-sized enterprises know that they do not know why. "If we do not complete pre registration within the specified time limit, enterprises will not be able to export to the EU from January 1, 2009."

Xie Zhaoming pointed out that early understanding of the relevant provisions of the regulations and the relevant requirements of the REACH regulations are very important for exporters, traders and manufacturers engaged in all trades and professions engaged in export.

In a random interview at the Canton Fair, reporters learned that SMEs' cognition of REACH is not optimistic.

The boss of an electronic information enterprise from Beijing believes that REACH is mainly a matter for material suppliers to deal with, which has little impact on the downstream businesses.

And a home appliance owner from Ningbo simply stated that he only knew about the EU RoHS directive on environmental protection (which limits the use of certain Hazardous Substances Directive) and EU (EU environmental protection badge certification), and had not heard of REACH regulations.

Compared with small and medium-sized enterprises, enterprises with large scale and rich experience in international trade have taken actions.

Mr. Chow, sales manager of Zhejiang Chi Di company, told reporters that he had been informed of the REACH regulations for a long time because he had done the export business of air conditioners. He had made environmental considerations in product design.

"It's really going to go up next year, and the cost is going to go up."

Zhou said that this law is like hanging a knife over there. The initiative is in the European Union.

Liang Shengmin, Jiangmen Jinling daily electric appliance company, said that since the quality and design of the products had been dealt with before, REACH had more customers in Europe after its entry into force.

"Some European customers have offered to look at upstream suppliers, the standards have been raised, and the selling price has naturally increased."

Liang Shengmin believes that REACH is not a bad thing. As long as the European Union treats all countries equally, the quality of the business depends on the enterprises themselves.

The Minmetals Association will set up a representative office to respond to REACH Xie Zhaoming's recommendation for enterprises. It should make good use of the pre registration stage from June 1st to November 30, 2008.

According to the regulations, pre registration can be produced or imported within the time limit prescribed by the registration, and the enterprises that register the same material can share data and data before formal registration, and jointly acquire the missing information and share the expenses, so as to effectively reduce the cost.

At present, the registration data required for the sale of chemicals under 1 tons or less and below 10 tons are not complicated and valid for 11 years, which can save a lot of money.

At the same time, domestic trade associations should give full play to their coordinating role, organize relevant enterprises to share information, and strive for pre registration.

In addition, different registration methods can be chosen, such as entrusting importers, law firms, intermediary agencies or domestic agencies abroad to assist in registration.

It is learned that, in order to enhance our enterprises' awareness of REACH regulations and understand and deal with the EU REACH regulations, the chamber of Commerce of the Minmetals Import and export association has organized specialized training for enterprises since last year, and will set up a representative office in Helsinki, Finland, at the end of 2007, to provide all kinds of relevant information for our government, industry and enterprises, and to provide agency services for Chinese enterprises in the European Union's product registration.

Background: why REACH has such a great lethality? Under the REACH framework, the burden of proof for the safety of chemicals is pferred from EU Member States to enterprises. Enterprises must ensure that they can fully control and avoid the risks of chemicals to human health and environmental protection.

REACH represents registration, assessment, authorization and restriction registration: Registration requires producers or importers to provide relevant information of more than 1 tons / year of chemical substances, including the submission of technical files.

There should be material information and how to manage the risk information in its use.

More than 10 tons / year of material is required to submit a chemical safety report to indicate its safety assessment.

Assessment: the assessment process will allow the competent department to decide whether to require further testing and evaluation, whether the information provided by the registrant is in compliance with the regulatory requirements (i.e. document evaluation), and to evaluate the selected substances, such as suspected risks to human health and environment.

This assessment provides a mechanism for the industry to get more information.

The assessment will also make recommendations for action under the authorization or restriction procedure.

Authorization: only those who are highly concerned need authorization.

Highly concerned substances refer to carcinogens, mutagens, toxic substances to reproductive systems, persistence, bioaccumulation of substances and toxic substances, permanent and high bioaccumulation substances and equivalent substances.

Limitation: restriction is the security barrier of this system.

Any substance, whether it is in itself or contained in products and articles, must be restricted within the community as long as the use of this substance has unacceptable risks to human health and the environment.

Its decisions include restrictions on the use of certain products, restrictions on consumer use or restrictions on all uses (i.e., complete prohibition).

The obligation of the business community requires that the producers or importers register those substances exceeding 1 tons / year, and the registration requirements apply to substances themselves, or substances (including strong emissions) contained in the products or articles under special conditions.

No registration means that the substance can not be produced or used in the EU, nor is it allowed to be imported into the EU market.

Downstream users of chemicals shall implement risk management measures for hazardous substances identified in the safety data sheets provided by the supplier.

They have the right to let manufacturers know how they use these substances so that the usage of these substances can be identified by suppliers, and will be covered to the chemical safety assessment of suppliers.

In this case, they must provide enough information for the supplier to prepare a description of the exposure plot for use.

The alternative to these practices is that they can carry out their own chemical safety assessment and report the use to the chemical administration.

The first stage of pre registration and formal registration: pre registration, from June 1, 2008 to November 30, 2008.

The second stage obligation: formal registration, according to the output and the degree of attention, the deadline is divided into three periods: November 2010, June 2013 and June 2018.