Application Of EU REACH Regulations In Shoes And Leather Industry

First, the EU reviews the history of some product recall. For example, this is the first example. You see the picture above. This is a Nantong sandal. In September 27, 2010, the product was recalled by the European Union because the product contained chemical risk. This example is from Czech and Czech, a country in the European Union. This example proves that the recall of these metals because of excessive nickel is to prove to everyone that the REACH regulations are not only for shoes manufactured outside the EU, but also for the production of shoes. EU internal production All of the shoes will be restricted by the REACH regulations.

This example is in 2010 August 20th, children's shoes from China. It contains over two methyl fumarate, which has been recalled. Now let's talk about the European Union's REACH regulations. REACH regulations can basically be divided into two parts. One is restricted substances, the other is the fourteenth chapter's authorization regulations.

Let's start with the restricted law of REACH. This rule came into operation in June 1, 2009, but the contents of these Regulations are not very new. As a matter of fact, these contents have been partially implemented in the past.

For many exports of shoes and leather products, these substances have also done a lot of attention in the past. Now we are going to see the inclusion of some restricted substances in the 17 chapter. What we see is azo dyes. This substance is usually used to prevent pollution or leather dyeing. If the substance exceeds the standard, it may cause carcinogenic effect on human body, and its substance content is 30PPM. Another example is called ortho benzene two formate, which can not exceed 0.1%. The other is nickel, which is usually in the metal plating layer. Nickel is measured by the amount of its release. The content requirement is that it can not release more than 0.5 milligrams per week in the space per square meter.

The REACH of the seventeenth chapter is summarized. We can see that the provisions of the 17 chapter of all REACH regulations have separate provisions for each substance. Moreover, the content of each substance is very clear, for example, azo element, its content is 30ppm, it is the restriction of the special material, that is to say, azo dyes are specially aimed at preventing or treating dirt or leather. It is very important that if your product contains more than the limit, your product can not be put into the EU market.

Now let's take a look at the fourteenth chapter of REACH, about authorized substances. The purpose of its regulation is to ensure that these highly concerned substances can finally be replaced by safer substances or technologies under the conditions of economic conditions and technological capabilities. This is the ultimate goal of the REACH regulations, but it takes a long time to complete, and it takes 10 to 15 years. This is European Union One goal.

I'm not going to show you the details in detail today. This is a very complicated chemical analysis. However, as long as the substances of high concern are chemical substances, they are very harmful carcinogenic. They are very harmful to the human body or to the environment. What is worth our attention is that up to now, more than 1500 potential substances of high concern have been discovered.
 

{page_break}

It can be seen that these substances which are currently highly regarded are relatively few. It may be that in the coming period, more substances will be listed in this form. We can see that in the past few years, what has been included in this highly concerned material is what we can see. Up to now, 53 substances have been listed as highly concerned substances.

For highly concerned substances, the EU continues to update, that is to say, every six months, the EU will add new substances. The REACH regulation is aimed at all consumers in the European Union not only for leather, or shoes, so it is easy to understand that these 53 substances of high concern are not all related to shoes or leather. This is a very important message. That is to say, we must pay attention to those substances that are really related to our industry.

In fact, for leather industry, REACH regulations are not so complicated. Now let me explain to you what substances are likely to be related to shoes and clothing. CTC, as an organization specializing in technology development and technical quality identification in the shoes and leather industry, we can first see that this substance belongs to a substance of PAH polycyclic aromatic hydrocarbons. There are other substances. Our shoe and leather industry is not very relevant, or we find it very small.

Now let's take a look at the highly concerned substances selected in chapter two. This substance is called phosphate. After that, let's take a look at the list of highly concerned substances in chapter five. Why? Because in fact, the correlation between shoes and third and fourth material lists is very low. We can see that here we use the red out substance, methyl pyrrolidine, we analyzed this substance, it may be higher than 0.1%. NMP this material, we should put in a very important position, and leather related degree is very high.

Another substance is a part of potassium phthalate. There are three substances in these substances which deserve our attention. The three red substances may be related to shoes and leather industry. At present, according to our analysis, it is not yet clear whether the substance will be included in the sixth chapter.

Now let's take a look at what responsibility we have to undertake for the REACH law. First of all, we have to communicate well with the supply chain. If your product is exported to Europe, then your product contains more than 0.1% of these highly concerned substances. This information needs to be communicated to your consumers. In Europe, every consumer has the right to know highly concerned material information in a product. All this information must be provided by the information requested by the EU consumers.

That is to say, the provision of information will put a lot of pressure on retailers in the European Union. Because they have to ensure that the products they are concerned with in the European Union can meet the requirements of the REACH law. Now we can see that the EU has a clear stipulation for this 0.1%. What he stipulated is that the contents of each of these 53 substances can not exceed 0.1% of the total weight of the products, but six countries do not fully agree with this definition, including France, Germany, Austria and so on.

Now let's go back to the form that we have shown you before. Let's make a comparison between the 14 and the 17 chapters of REACH. As you can see, the restricted substances on the left and the authorized substances on the right. For authorized substances, the requirement is that the content of the authorized substance can not exceed 0.1% for all kinds of products. A very important point is that if your product contains more than 0.1% of the authorized material, you can actually be put on the market. But you must provide the necessary communication, which we need to understand.

Importers need to provide this information to your retailers and retailers to your customers.

Let's talk about how this regulation is implemented. We see this 126 rule stipulating that every member state of the European Union should make the punishment provisions in the host country. Why? It is because the 27 European Union countries have their own independent legal system. We can see that some countries in the European Union are very strict and very heavy in punishing the enforcement of REACH regulations. For example, Western Europe's Germany, France and so on.

However, some countries are very light on the enforcement of the law, so it depends on which country your products are exporting to the European Union.

The last part, the introduction of REACH, is about market regulation. Generally speaking, it is considered that the customs is supervising and inspecting all products entering and leaving the European Union. But you can understand that the customs of the European Union need to deal with a lot of goods every day, so they are not likely to control every product. So in fact, the regulation of the market is called NGO NGOs in the market regulation. These non-governmental organizations, for example, see the chemical health inspection network. These NGOs will take the initiative to pick up one of their products at any retail store in Europe and then go to a laboratory for testing. If the product is detected to contain substances that are more than the European Union's REACH law, it is obvious that the brand will suffer very great harm.

If the product is detected exceeding the standard, they will write the name on the website. This is another NGO. You can see that there is a template letter on the left hand side of the website. Every retailer in Europe asks his retailer to produce relevant information and must respond to the requirements of consumers. So it's very simple to teach European citizens how to get the chemical information they need in the simplest way.

In this way, such non-governmental organizations have effectively supervised the implementation of REACH regulations.

I mentioned the RApex website before, describing the recall of all consumer goods in Europe, which do not comply with the EU's REACH regulations. You can find examples of previous or recently recalled products.

As I said today, CTC is a testing and technical organization specializing in leather and shoes. We have a complete R & D system for leather products and shoes. At present, we have 3 laboratories in China. In Dongguan, Shanghai and Hongkong, if any department of information understands or needs to know us, we will be happy to do it for you.