Experts Explain The EU'S Registration, Assessment, Licensing And Restriction Act On Chemicals.

The European Union's REACH regulations on the registration, assessment, licensing and limitation of chemicals (Registration, EvaluationandAuthorizationofChemicals) was adopted by the European Union in December 13, 2006 and will be formally implemented in June 1, 2007.

At that time, it will replace the existing directive and regulations on chemicals, such as the classification, packaging and labelling directive of the European Union, which will require registration, evaluation and licensing of all chemicals in the EU market and into the EU market and implement safety monitoring. 40

It is estimated that, because of REACH, the trade between China and the EU will be affected by 140 billion euros. All household appliances, textiles, clothing, footwear, toys, light industry, electronics, automobiles and pharmaceuticals will all be affected and hurt. The trade pattern of China and Europe and even its upstream and downstream industries will face a major reshuffle.

China's enterprises are puzzled: first, the scope of regulation and control. The EU REACH code is known as the "chemical registration, evaluation, licensing and restriction bill". Many domestic enterprises (especially Electromechanical, household appliances, electronics, toys, clothing industry) have come to the conclusion that REACH regulations are only related to petroleum, chemical, pharmaceutical and other industries.

In fact, REACH regulations require that chemical substances, whether they exist independently or in various products, require authorization or restricted use. If substances or products are required to be registered, if they are goods, they need to inform and pmit information.

As a result, up to 5 million kinds of products have been affected, covering almost all products including electromechanical, household appliances, textiles, furniture, toys, cosmetics, daily chemicals and so on.

In addition, in accordance with the provisions of the REACH regulation, the total amount of 1 tons of chemical substances or products exported to the EU will need to be registered, otherwise it will be banned from entering the EU market.

This is the principle of "no data, no market" in REACH regulations.

At present, most of the chemical products exported to the EU each year exceed 1 tons.

Therefore, the products exported to EU basically belong to the jurisdiction of REACH regulations.

There are about 100 thousand basic chemical substances in the REACH regulations. There are about 30 thousand kinds of substances in excess of 1 tons / year, which are listed as highly concerned substances, which are commonly referred to as 1500 kinds of toxic and harmful substances.

The previous RoHS regulations only restricted the use of 6 kinds of toxic and harmful substances. Domestic enterprises have already felt a lot of pressure. Now the REACH regulations extend the materials that need to be authorized or restricted to more than 1000 kinds of enterprises, and enterprises will be more difficult to cope with.

Chinese enterprises doubt two: implementation timetable, according to the timetable for implementation of REACH regulations, REACH regulations will take effect in June 1st this year, and will be pre registered from June 1, 2008 to November 30, 2008.

From December 1, 2008, unregistered or pre registered products will be banned from entering the EU market.

However, many enterprises believe that there is still a period from the actual implementation.

Many companies think that the REACH regulation is a matter of government departments. They expect the government to organize the response, or expect other enterprises to explore the road first.

In fact, the key to the release of substances in materials, products and articles is registration. About 80% of the chemical substances need to be registered only. However, the preparation for carrying out registration procedures is very cumbersome. For example, enterprises must first understand the list of chemical substances contained in their products, expose the feasibility analysis, carry out chemical safety assessment and chemical safety report writing, toxicological and ecotoxicological tests, etc. each work can take one or two years.

In addition, for highly concerned substances (SVHC), such as the use of more lead in the electronics industry, we need to notify, pmit information and apply for authorized use.

If enterprises are lead-free, a plan should be submitted to clarify the timetable for replacement.

The product will be banned from entering the European Union if it is not authorized or the submitted audit is not approved.

Unlike EU directive RoHS, REACH regulations are mandatory, and products that do not complete registration procedures will be banned from entering the EU market.

At present, it is 2008 August, pre registration has only more than 3 months, but most of the enterprises in China still have not registered preparation work.

Experts worry that if we do not act immediately and miss the registration time, enterprises will either withdraw from the EU market or pay a higher price.

Chinese enterprises doubt three: registration and testing fees. According to the EU estimates, the basic inspection cost of each chemical substance is about 85 thousand euros, and the cost of each new chemical examination is about 570 thousand euros, plus registration fees, which is very expensive.

If a product involves several hundred or hundreds of chemicals, the cost will be astronomical and no enterprise will be able to bear it.

Some companies worry about the huge cost, feel helpless, and even abandon the idea of the EU market.

In fact, as long as we use the pre registration procedure set up by the REACH system, we can avoid the high cost problem.

For example, the pre registration of enterprises from June 1, 2008 to December 1, 2008 will become a potential registrar not only to enjoy the registration grace period ranging from 3 to 11 years, but also to participate in the Forum on material information exchange and become one of the sponsors of chemical substances registration.

Through information exchange, avoid repeated tests and reduce the cost of testing.

At the same time, it can share the cost with other enterprises, thus greatly reducing the cost of testing and registration.

There is no high cost for enterprises that actively participate in pre registration.

In this regard, the experts of China's inspection and Quarantine Bureau also reminded enterprises to fully recognize the benefits of pre registration.

At present, the most important task for an enterprise is to communicate with the upstream and downstream customers as soon as possible, analyze the products exported to Europe as early as possible, and understand the total number of products exported to Europe.

Find out whether your products are included in the chemical inventory of REACH regulations, whether registration, notification, authorization, etc., as well as the data and information required to register, are in order to act in line with the REACH law.

If the domestic enterprises do not have a branch in the European Union, they need to find the third party institutions with the sole representative qualification to help themselves to register for REACH. At present, Intertek group has provided the "sole representative" service to the market.

Chinese enterprises doubt four points: enterprise obligations and countermeasures. China's export of electronic and electrical appliances, toys, furniture, textiles and other products, according to the REACH regulations are belongings, need to consider REACH's notification, pmission of information and other obligations.

The relevant laws and regulations are as follows: 1. Bulletin (clause 7 (2)) should be notified in accordance with the following conditions: 1 tons / year 0.1% (w/w) two, and delivery of information (33 (1) and 33 (2)) 0.1% (w/w), it is necessary to provide the receiver with the chemical name of SVHC (SVHC), how to use the material information of 0.1% (w/w) safely, after receiving the request, the relevant information should be provided free within 45 days.

However, enterprises can choose some high-risk substances for testing, such as azo dyes, PAHs, PFOS, NP, VOCs and so on.

Intertek group provides high-risk substance testing services, and provides detailed notification and pmission information requirements, tonnage calculation methods and items to deal with REACH training services and SVHC.

It can help enterprises to prepare for the implementation of REACH regulations and smooth pition.

Summary: from the current market situation, most Chinese enterprises do not understand the REACH regulations or wait for the government and industry associations to organize and call.

Experts warn that REACH regulations are mandatory regulations. If enterprises fail to act immediately and miss registration time, they will face a crisis of losing EU market share.