REACH 2018 and after. CLEPA Materials Regulations Event. 19 April Monique Pillet Scientific Officer

Transcription

1 REACH 2018 and after CLEPA Materials Regulations Event 19 April 2018 Monique Pillet Scientific Officer

2 Overview REACH 2018 Communication in supply chain Substances in articles 2

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4 What do we expect? Many more registrations Less companies registering the same substance Higher % of SMEs Less information need to generate new data

5 What do we expect? Extended processing time (3 months from deadline) Dossiers (estimate) Substances (estimate) >8000 dossiers/week Normal Completeness Check Until 1 April (21 days) Deadline completed Number of dossiers received 350 dossiers/week 150 dossiers/week 250 dossiers/week 9 th April: Regs Subs 1 April 1 Jun 3 Sep Deadline

6 REACH 2018 snapshot registrations received for substances Registrations from SMEs: 21% in March Many registrations from outside of EU: 43% from importers and 29% from OR Indications of late activity: High number of disputes, inquiries and exceptional cases Around 20% below expected number of registrations at this date Figures as of 9 th April

7 Follow the progress echa.europa.eu/registration-statistics-infograph# 7

8 Need support? REACH 2018 webpage Contact your national helpdesk Contact ECHA 8

9 Helping companies in exceptional situations Description of the issue Mixture importer does not obtain substance identification information from non-eu supplier Delays in obtaining test results in time for the deadline Legal entity change: company without pre-registration Lead registrant fails to submit a complete registration Substance with no registration intentions: Downstream user decides to start importing and needs to register Further information and instructions at: echa.europa.eu/about-us/partners-and-networks/directors-contact-group 9

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11 Communication in the supply chain Upstream Manufacturer Importers Downstream Information on uses Formulator Formulator Information on safe use End user Users of articles 11

12 Is it important? The effective communication between all levels of the supply chain is vital. Definite contacts need to be in place between organisations enabling the transfer of chemical safety data from the importer or manufacturer down the supply chain. Safe use of chemicals Industry M/I Registrant Downstream user Registration Public Authorities User of articles 12

13 Working together on solutions Suite of tools for improving communication in the supply chain Key actors involved DUCC/Cefic/Concawe/ Eurometaux/ECHA 13

14 How to contribute? ENES Work Programme to 2020 Towards good quality information on the safe use of chemicals in the REACH chemical safety report and the extended safety data sheet Information DU Registrants use maps Information processing by Registrants exposure modelling, Formulators SUMI, LCID, consumer use End users mixtures, articles, information needs across legislations To be published in April at 14

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16 Substance, mixture or article? Article: object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. Containers = Articles Paint, oil = Substance or mixtures 16

17 Articles can be assembled Mixture M mechanically or using a substance/mixture to become a complex object 17

18 SiA REACH requirements Candidate List substances Notification to ECHA: CL substance and present in article above 0.1% and total amount exceeds 1 tonne per year Communication to customers: CL substance present in article above 0.1%, sufficient information to allow safe use of the article Intended release: registration needed when over 1 tonne per year Restrictions: compliance with relevant restrictions Webpage, guidance document, webinar 18

19 SiA current topics 1. European court of justice decision ECHA guidance 2017 ACEA sector guidance 2. Enforcement ongoing pilot Notification and communication obligations State of play, better understanding, more experience Inspections Oct 2017 Dec 2018, report end Feb Revision of Waste framework directive DB on SVHC in articles, including at waste stage 19

20 Key messages 2018 deadline is one step REACH journey continues Communication in the supply chain is a key pillar of REACH contribute to it Substances in articles ensure safety to users of articles

21 Thank you! monique.pillet(at)echa.europa.eu Subscribe to our news at echa.europa.eu/subscribe Follow us on Follow us on Facebook Facebook.com/EUECHA