EU REACH Regulation Amendment Proposal Footwear Export Restricted Again

Recently, Ningbo Inspection and Quarantine Bureau reported that the EU has recently passed the amendment proposal of REACH regulation again, which will expand the limitation range of polycyclic aromatic hydrocarbons. Previously, REACH regulations limited the content of polycyclic aromatic hydrocarbons to only one class of products, that is, the content of polycyclic aromatic hydrocarbons in tire filling oil. That is, from January 1, 2010, if the content of eight kinds of polycyclic aromatic hydrocarbons, including benzo (a) pyrene and benzo (a) anthracene (BaA), in tires and oils used in tire manufacturing exceeds 10 mg/kg, or benzo (a) anthracene (BaA)（ а) Pyrene containing more than 1 mg/kg shall not be sold. The new proposal will expand the products to dozens of categories, including: electric tools, household appliances, trolleys, walking frames, clothing, shoes, gloves, wristbands, wristbands, masks, headbands, as well as bicycles, golf clubs, rackets and other sports equipment.

Compared with the original regulations, the restricted substances are still 8 kinds of polycyclic aromatic hydrocarbons, but the limit of any kind of polycyclic aromatic hydrocarbons has been reduced by 10 times, from the original 10 mg/kg to 1 mg/kg; The limit of toys, children's sports equipment and other children's products was even reduced to 0.5 mg/kg.

Polycyclic aromatic hydrocarbons (PAHs) are organic compounds with strong carcinogenicity, mutagenicity and reproductive system hazards, including more than 150 compounds such as naphthalene, anthracene, phenanthrene, pyrene, etc. They are widely found in petrochemical products such as plastic rubber, crude oil, lubricating oil, antirust oil, film remover, gasoline retarder, mineral oil, cypress oil, pesticides, charcoal, fungicides Mosquito incense and other daily chemical products. In the electronic and electrical manufacturing industry, polycyclic aromatic hydrocarbons are often used as release agents and other plastic additives into the production process.

EU PAHs testing has always been a "barrier" for China's tire exports. This REACH regulation's expansion of the range of controlled products will undoubtedly further build a barrier for the export of many types of products. However, due to the process gap and lack of research and development capabilities, most domestic enterprises cannot produce aromatic oil that meets the EU's requirements independently, and have to import environmental friendly aromatic oil products from Europe and the United States, The difficulty of product cost control has increased, and the factors of export instability have greatly increased.

The inspection and quarantine department reminds that light industrial and textile products such as electric tools, clothing and shoes, bicycles, etc., have always been the highlight of Ningbo's export, with an annual export amount of more than 2 billion dollars to Europe. With the approaching of the effective date of EU regulations, the negative impact caused by the difficulty in testing PAHs will be further amplified. In order to solve this problem and improve the sustainability of exports, enterprises should attach great importance to it and take precautions. First, establish an effective risk early warning and quick response mechanism, establish an audit and evaluation system for raw and auxiliary material suppliers, and improve the quality safety system and lean control management. The second is to strengthen the control and optimization of the production process, strengthen the strict control of the three links of design, production process control and project detection, in particular, do a good job in the qualification test of toxic and harmful substances in the later period, improve the self inspection, self-control and safety risk research and assessment capabilities, and prevent the chemical content from exceeding the standard. Third, on the basis of actively absorbing foreign advanced technology, with the joint efforts of research institutions and third-party platforms, we should integrate advanced ecological design concepts into the development of environmental protection alternatives, improve our independent research and development capabilities, and ensure the smooth progress of trade to Europe.