Tag: chemicals registration

February 11, 2022

Four new hazardous chemicals added to the SVHC Candidate List

ECHA has added four new entries to the Candidate List of substances of very high concern on 17 January 2022. Substances of Very High Concern (SVHC) may have serious and often irreversible effects on human health and the environment. There are currently 223 substances or groups of chemicals on the SVHC Candidate List.

Newly added substances are used in products such as cosmetics, rubbers, lubricants, and sealants. The substances have been added to the Candidate List due to their hazardous properties to human health or the environment.

Hazardous chemicals added to the Candidate List

Substance	EC/CAS number	Uses	Reason for proposing
6,6′-di-tert-butyl-2,2′-methylenedi-p-cresol	EC 204-327-1, CAS 119-47-1	Rubbers, lubricants, adhesives, inks, fuels	Toxic for reproduction (Article 57 c)
tris(2-methoxyethoxy)vinylsilane	EC 213-934-0, CAS 1067-53-4	Rubbers, plastics, sealants	Toxic for reproduction (Article 57 c)
(±)-1,7,7-trimethyl-3-[(4-methylphenyl)methylene]bicyclo[2.2.1]heptan-2-one covering any of the individual isomers and/or combinations thereof (4-MBC)	–	Cosmetics	Endocrine disrupting properties (Article 57 f – human health)
S-(tricyclo(5.2.1.02,6)deca-3-en-8(or 9)-yl O-(isopropyl or isobutyl or 2-ethylhexyl) O-(isopropyl or isobutyl or 2-ethylhexyl) phosphorodithioate	EC 401-850-9, CAS 255881-94-8	Lubricants, greases	PBT (Article 57 d)

Obligations related to SVHC

Companies have legal obligations if a substance included in the Candidate List is present in a concentration above 0.1% w/w. Obligations include:

Providing Safety Data Sheets for substances on their own and substances in mixtures containing SVHCs
Requirement to notify ECHA under REACH if an article contains a SVHC
Requirement to inform customers and consumers under REACH if an article contains a SVHC to allow safe use of the article
Requirement to notify ECHA under the Waste Framework Directive (SCIP Database) about articles containing SVHCs

Companies that are importing, producing, selling, or using substances, their mixtures, or articles (components, materials) containing SVHCs should keep an eye on the substances added to the Candidate List. Substances are regularly being added to the list. It is also recommended for companies to start looking for substitutes for the added substances already. Substances on the Candidate List may also be placed on the Authorisation List in the future, which means that continuing the use would need a permission.

Do you need help with chemical management?

Our experienced chemical consultants will assist you in meeting your chemical requirements. Furthermore, our Ecobio Manager SaaS-service will help you manage your chemicals and ensure compliance with global regulations. Interested? Contact us today!

Contact: info@ecobio.fi

Text: Mikael Hirn

Image: Unsplash

References

ECHA: Four hazardous chemicals added to the Candidate List.

TUKES: Erityistä huolta aiheuttavat aineet (SVHC).

October 18, 2021

Safer Chemicals Conference 2021

The European Chemicals Agency (ECHA) organized a virtual Safer Chemicals Conference on 6 October 2021. Ecobio attended the event.

The conference focused on the chemical strategy and several related themes, which will affect e.g. the chemicals legislation and substance restrictions. The goal is a non-toxic environment where chemicals contribute to society while avoiding harm to the environment and humans. Three core issues of the chemicals strategy are 1) increasing the protection of the environment and people 2) innovation and 3) simplifying and consolidating the current legal framework.

The issues raised by the conference presentations and speeches included:

New safe chemicals and materials are needed, and innovation is an integral part of it.
Definition and criteria for a sustainable chemical are needed. Criteria must be introduced.
Research funding should support the development of safe and sustainable chemicals.
The chemicals strategy is not only about sustainability, but also includes measures for the circular economy and digitalisation.
A full life cycle assessment of chemicals is needed to ensure safety and sustainability.

The presentations addressed the grouping of substances to speed up and harmonize restrictive measures, the replacement of hazardous solvents by less harmful ones, PFA restrictions, the new Clean Drinking Water Directive, and nanomaterials. In addition, PCN and SCIP notifications and changes made in relation to them were reviewed.

Additionally, one of the themes of the event was compliance. Conformity and enforcement of products and chemicals will be strengthened through more frequent checks. ECHA supports companies in compliance e.g. with informal reviews through the Voluntary Action Plan.

The new features of PCN notifications for hazardous mixtures were reviewed. For example, it is possible to make notifications for several mixtures at the same time, provided that they have the same classification. Discontinuation of the product may also be indicated in the notices. Furthermore, new situations where the notification needs to be updated were discussed. Updates have also been made to the PCN format and the submission of notifications has been improved, e.g. through the System-to-System (S2S) service.

Obligation for notifying on Substances of Concern In articles as such or in complex objects (Products) was discussed as well as the preparation of the notification, and the public SCIP database and its use. A SCIP notification or a Simplified SCIP notification (SSN) must be made for articles containing more than 0.1 % of any Substance of Very High Concern (SVHC). Companies’ challenges in the SCIP notification obligation include the relatively short notice that was given to prepare for the new obligation and gather the necessary information in complex supply chains. Despite the difficulties, a significant number of SCIP notifications have already been made to the SCIP database.

In addition, the concerns of the companies were heard in the discussions and chat rooms of the event. The following ideas were put forward:

Companies need clear criteria and direction to invest in as quickly as possible. It takes time to achieve the given goals and make the necessary changes.
There must also be a market for sustainable and safe chemicals. Companies may face questions such as: How much more can a sustainable chemical cost? How much of the product’s properties are allowed to deteriorate?
In companies, a decrease in the consumption of chemicals may mean a decrease in growth.

The materials and recordings of the event are available at ECHA’s website here.

Text: Anne Kallioinen & Mikael Hirn

Picture: Shutterstock

October 8, 2021

Poison Centre Notification – 6 Steps for a Successful PCN

Download our comprehensive guide about Poison Centre Notification here!

A large number of chemical products are placed on the EU market and used both by the general public in their everyday lives as well as by professionals in their working environments. Chemical products are, in general, considered to be safe when their use instructions are followed. Nevertheless, unintentional exposure to chemicals can occur, for example, due to their inappropriate use or accidents. When this happens, immediate access to relevant information on the chemical product is crucial for medical staff and those who provide emergency responses. Poison centres play an important role in ensuring the safe use of chemicals and formulating preventive and curative measures for poison incidents.

The companies that place hazardous mixtures on the market are obliged to provide information to the poison centres in each EU member state the placing occur. The placing on the market happens when the company, e.g. formulates or imports a mixture and either sells it or uses it in its own operations. This requirement is set by law in article 45 of the Classification, Labelling and Packaging (CLP)regulation ((EC) No 1272/2008). This obligation is applicable to mixtures,e.g. to detergents, paints, glues or biocides. Substances, e.g. ethanol, hydrogen peroxide, or copper sulphate, are not in the scope of this obligation as poison centres have the required information of substances available in their databases. The information provided enables poison centres to advise the citizens or medical personnel in an emergency.

PCN plays an important role in ensuring the safe use of chemicals and formulating preventive and curative measures for poison incidents

Our guide gives an overview of Poison Centre Notification (PCN) that play an important role in ensuring the safe use of chemicals and formulating preventive and curative measures for poison incidents.

Do you want to know what a Poison Centre Notification (PCN) is? Are you curious about which mixtures require information to be submitted and how to submit a Poison Centre Notification dossier? These are just some of the questions our guide answers as well as presenting the 6 steps for a successful PCN.

Download our guide by filling in the form below.

Picture: Shutterstock

July 12, 2021

Eight new hazardous chemicals added to the SVHC Candidate List

ECHA has added eight new entries to the Candidate List of substances of very high concern on 8 July 2021. Substances of Very High Concern (SVHC) may have serious and often irreversible effects on human health and the environment. There are currently 219 substances on the SVHC Candidate List.

Newly added substances are used in consumer products such as cosmetics, scented articles, rubber, textiles, solvents, flame retardants or to manufacture plastic products. Most of the substance have been added to the list due to their hazardous properties to human health.

Hazardous chemicals added to the Candidate List

Obligations related to SVHC

Companies have legal obligations if a substance included in the Candidate List is present in a concentration above 0.1% w/w. Obligations include:

Providing Safety Data Sheets for substances on their own and substances in mixtures containing SVHCs
Requirement to notify ECHA under REACH if an article contains a SVHC
Requirement to inform customers and consumers under REACH if an article contains a SVHC to allow safe use of the article
Requirement to notify ECHA under the Waste Framework Directive (SCIP Database) about articles containing SVHCs

Companies that are importing, producing, selling or using substances, their mixtures or articles (components, materials) containing SVHCs should keep an eye on the substances added to the Candidate List. Substances are regularly being added to the list. It is also recommended for companies to start looking for substitutes for the added substances already. Substances on the Candidate List may also be placed on the Authorization List in the future, which means that continuing the use would need a permission.

Do you need help with chemical management?

Interested? Contact us today!

Contact: info@ecobio.fi

Text: Mikael Hirn

Picture: Shutterstock

References:

ECHA: Candidate List updated with eight hazardous chemicals.

TUKES: Erityistä huolta aiheuttavat aineet (SVHC).

May 3, 2021

Ecobio’s key take-home messages from the Helsinki Chemicals Forum 2021

This year’s Helsinki Chemicals Forum (HCF) took place virtually on the 27^th and 28^th of April. Ecobio also joined the Forum as probably many of you too. In this brief blog we would like to share with you what we got out of the lively discussions during the two days. In these take-home messages, we concentrate in the EU’s Chemicals Strategy for Sustainability. This is because it was by far the most heavily debated topic at the HCF.

As we all know, the EU’s new growth strategy, the European Green Deal, has set the European Union (EU) to become a sustainable climate neutral and circular economy by 2050. Therefore, it sets the goals to tackle pollution and move towards a toxic-free environment. The EU’s Chemicals Strategy for Sustainability (CSS), published in October 2020, is part of this scope. Not only because the chemical manufacturing industry is the fourth largest sector in the EU, but also because the chemicals are used in 95% of all manufactured goods.

Safe and sustainable-by-design to protect human health and the environment

The future chemicals have to be safe and sustainable-by-design, the CSS outlines. Although the actual meaning of this is yet to be defined in the EU, the debate during the HCF was around the following lines. New green chemistries need to be developed and used to produce new types of molecules to replace the most harmful current ones. The safe and sustainable-by-design concept needs to go through the entire life cycle of the chemical. For example, at the sourcing stage of the raw materials, the workers’ safety and human rights need to be adhered, and similarly at the manufacturing stage, too. The manufacturers also need to produce their chemicals, materials, and products environmentally friendly, e.g., by using renewable energy sources.

The safe use of the chemicals, materials and products must be guaranteed. In the final stage of their life cycle the waste must be recycled in a manner that contributes to the circular economy. Information and transparency from the start to the end of product’s life are the key. Currently, we do not know anything about 70% of the chemicals, which was reminded at the HCF. Some speakers pointed out that without the right information through the entire product-chain we would not know how to appropriately recycle the waste in the end, in particular of the long-lasting materials such as concrete. As a starting point to improve this and to enable consumers to make informed choices, ECHA is going to make the data in its SCIP-database publicly available by the end of this year.

Innovation and funding are prerequisite for the new developments

The CSS promotes innovation to develop the new chemicals of safe and sustainable-by-design. It was made clear during the HCF discussions that funding is needed at all fronts from the development to manufacturing until the waste management. The EU will provide funding for these innovations; they could be e.g., new green chemistries, new greener technologies at the manufacturing sites or novel ways to decontaminate waste.

Voices were heard at the HCF that funding is highly important. Concerns were raised how competitive the EU’s future chemicals sector would be if the non-EU-economies do not follow similar green strategies. It was also pointed out that chemicals sector will face many challenges simultaneously between now and 2050: green and digital transition challenge, circularity challenge and CSS. The CSS is a bigger regulatory update than REACH ever was, some HCF speakers noted. It was acknowledged, however, that the CSS gives a great opportunity for the EU’s chemical industry to be a global front-runner.

Essential use of the chemicals is the way forward

The CSS brings forward the concept on the essential use of the chemicals. Again, this is yet to be defined by the EU. Nevertheless, it was discussed in the HCF that in the evaluation process of the chemicals, the essentiality of their uses should also be assessed. The CSS outlines that the essential use must be a justified use where the most harmful chemicals are only allowed if their uses are necessary for health, safety or are critical for the functioning of society, and if there are no alternatives. Examples were given from the medical device sector; while the same harmful chemical used in a medical device could be considered essential, in the consumer products it should be banned.

The CSS clearly aims at ensuring with the generic risk management approach that consumer products such as food contact materials, toys, childcare articles, cosmetics, detergents, furniture, and textiles, do not contain chemicals that cause cancers, gene mutations, affect the reproductive or the endocrine system, or are persistent and bioaccumulative. To empower this, the substances will be assessed and regulated in groups, instead of one-by-one. This will speed up the assessments made by ECHA, and consequently increase the number of restricted substances. Concerns were raised by some HCF speakers, whether this approach to regulate chemicals in groups would lead to omission of the essential uses of some specific chemicals. Time will tell.

PFAS and endocrine disrupters in the spotlight

Special attention is given by the CSS to PFAS and endocrine disruptors (EDs). The aim is to ban the use of PFAS as a group in the EU, unless proven essential for the society. As regards to the EDs, their all non-essential uses will be banned in the consumer products. The discussions are ongoing to introduce a new hazard class on endocrine disruptors in the CLP-regulation, based on the WHO definition, but building on the present criteria currently applied to pesticides and biocides. At the HCF, it was asked whether this new class would effectively be better to be added to the UN’s GHS to avoid the differences.

REACH will be re-opened in 2022

To allow the regulatory changes described by the CSS, the REACH-regulation will be revisited and amended accordingly. Information requirements are expected to increase. The CSS points to the direction to extend the REACH scope to cover certain polymers of concern, such as with CMR or ED properties. Also, information on the overall environmental footprint of the chemicals (e.g., emissions of greenhouse gases) would be required and more information will be needed to enable effective identification of the critical hazards of the substances (e.g., neurological effects).

The future REACH will also require data to enable identification of all carcinogenic substances manufactured or imported into the EU irrespective of their volumes. Furthermore, compliance of all REACH-registration dossiers is required. This is to strengthen the principles of “no data, no market” and the “polluter-pays”. In case of non-compliance, the registration numbers will be revoked. Mixtures of the chemicals will also be introduced in the updated REACH, considering also other relevant legislation. E.g., food additives, food contact materials, water, cosmetics, and detergents. To involve the other regulatory sectors better, one-substance-one-assessment approach will be employed by building the new assessment on the previous assessments of the substance. Finally, the ongoing discussions on the introduction of the worker safety legislation into REACH were further reiterated at the HCF.

This is what we at Ecobio found to be the most relevant discussion points at HCF 2021. Hope you enjoyed the reading. Next HCF will be held in March 2022 and thereafter every second year. You can find the CSS here and the CSS action plan here.

Do you need help with chemical management?

You can contact us through email at info@ecobio.fi or by phone +358 20 756 9450.

You might be interested in our chemical management webinar on Thursday 6.5.2021

Welcome to our webinar regarding the digital future of chemical management on Thursday the 6^th of May 2021. In our webinar our we summarize chemical risks for companies as well as their management in the workplace. Our experts present the most common challenges and digital solutions regarding complying with chemical laws. Additionally we go trough managing the use of chemicals and assessing the risk of chemical exposure. The webinar is held in both Finnish, Swedish, and Norwegian.

Read more and register using the links below:

You can find all of our upcoming and recorded webinars from our webinar library here!

Text: Mari Eskola, Dr, Senior Consultant

Picture: Shutterstock

March 31, 2021

ECHA has opened a public consultation over eight potential substances of very high concern

ECHA has released proposals to identify eight chemical substances as Substances of Very High Concern (SVHC). Substances that may have serious and often irreversible effects on human health and the environment can be identified as SVHCs. If a substance is identified as an SVHC, it will be added to the Candidate List of REACH for eventual inclusion in the Authorisation List. Currently there are 211 substances on the SVHC Candidate List.

The proposed substances and examples of their use are:

More information about the substances and links to comment are found at the ECHA website. The deadline for comments is 23 April 2021. Comments received on uses, and volumes per use, exposure, alternatives and risks will be taken into account in the authorisation process. Proposal and comments are referred to the Member State Committee (MSC) for agreement. If the committee does not reach a unanimous agreement, the matter is referred to the European Commission for a final decision. The substance is included directly in the Candidate List if no comments challenging the identification are received.

Obligations related to SVHC

Companies have legal obligations if a substance included in the Candidate List is present in a concentration above 0.1% w/w. Obligations include:

Providing Safety Data Sheets for substances on their own and substances in mixtures containing SVHCs
Requirement to notify ECHA under REACH if an article contains a SVHC
Requirement to inform customers and consumers under REACH if an article contains a SVHC to allow safe use of the article
Requirement to notify ECHA under the Waste Framework Directive (SCIP Database) about articles containing SVHCs

Companies that are importing, producing, selling or using substances, their mixtures or articles (components, materials) containing SVHCs should keep an eye on the substances added to the Candidate List. Substances are regularly being added to the list. It is also recommended for companies to start looking for substitutes for the added substances already. Substances on the Candidate List may also be placed on the Authorisation List in the future, which means that continuing the use would need a permission.

Do you need help with chemical management?

Contact: info@ecobio.fi

Text: Mikael Hirn

Picture: Shutterstock

Sources:

ECHA Weekly – 10 March 2021.

TUKES: Erityistä huolta aiheuttavat aineet (SVHC).

February 19, 2021

ECHA extends the scope of completeness check to include chemical safety reports

The Technical Completeness Check (TCC) done by ECHA for each REACH registration dossier now includes manual checks on the content of chemical safety reports. The extended completeness check will apply to both new registrations and updates of existing ones. Implementation of the revised completeness check was originally planned for November 2020 but was postponed until 2021. This TCC improvement aims to enable better prioritisation of substances for regulatory action by authorities and to improve supply chain communication. Companies are responsible for registering substances that are manufactured or imported above one tonne a year.

What is completeness checking?

ECHA carries out a TCC on each incoming registration dossier to ensure that all required information is provided. The completeness check includes a manual verification which means that ECHA checks certain elements of the registration dossier that cannot be checked automatically. The TCC process, applied to all registration dossiers submitted to ECHA, previously included only the following elements:

Substance identification
Data-waiving justifications
Testing proposals on vertebrate animals
Justification for opting-out
Specific requirements for nanoforms

As of 1 March 2021, manual completeness checks performed by ECHA staff will be extended to chemical safety reports to ensure they contain all the elements required under REACH. A chemical safety report is required for all substances subject to registration in quantities of 10 tonne a year or more per registrant. Exposure assessment and risk characterisation are checked from chemical safety reports. Since the chemical safety report is submitted as a text document attached to the IUCLID dossier, the information cannot be verified by the Validation assistant. This makes verifying the completeness of a dossier before submitting more difficult. Registration dossiers sent before 1 March 2021 are not checked for the new TCC rules.

Registrants should, therefore, prepare for the changes, as their update registrations may no longer pass the revised technical completeness check. If your first submission fails the TCC, you will get four months to correct the information. If your second submission is also incomplete, your submission will be rejected, and the data will not be included in ECHA’s database. ECHA will not refund or otherwise credit any fees before the rejection.

More information

Technical Completeness Check: https://echa.europa.eu/technical-completeness-check

ECHA’s webinar on the revised completeness check: https://echa.europa.eu/-/revised-completeness-check-what-changes-and-how-you-can-prepa-1

Do you need help with chemical management?

Contact: info@ecobio.fi

Text: Mikael Hirn

Picture: Shutterstock

Source: ECHA

June 20, 2018

Blog: REACH – ripple effects on the whole supply chain

An important milestone for the European chemical industry has been reached as the final REACH registration deadline for substances passed in 31.5.2018. The European REACH Regulation ((EC) No 1907/2006), however, continues to set high standards for the whole industry, from manufacturers, importers, formulators and distributors all the way down to downstream and end users.

Effects on the supply chain

Whilst the REACH registration deadline passed in 31.5.2018 already, it can take up to 3 months for the European Chemicals Agency ECHA to make a registration decision; your supplier might be fully REACH compliant if they have submitted their dossier on time, but might not yet have received a registration decision, i.e. a registration number, from ECHA. In complex cases where an extension might have been received from ECHA and the Director’s Contact Group, receiving a registration decision will take even longer than that.

This also means that the potential effects of the last registration deadline that mainly dealt with SMEs and their substances might affect supply chains with a delay. Whether or not the registering company had enough assets and know-how to pull through the registration might become evident only later on. If a company has decided to cease their manufacture by 31.5.2018, they are still allowed to sell all their supply gathered before the deadline to downstream users as distributors. Whether or not some companies or some products might be dropping out, or the market become more homogenized, will most likely be found out only after the dust of the final registration deadline has settled.

Communicating REACH compliance to authorities and stakeholders

In terms of supply chains and their continuance, it is important to notice that pre-registration numbers are no longer valid. It is also important to notice that either a generic or a company-specific version of the actual REACH Registration number can be put forward. The company-specific version always consists of four parts of numbers, e.g. 01-2119458769-17-0003, whereas the generic form might only consist of three (e.g. 01-2119458769-17 or 01-2119458769-17-XXXX). Make sure that your suppliers have actually registered the substance in their name, and are not just giving you a generic number to keep you content for a while.

A good way to communicate a company’s adherence to REACH and its many requirements is a REACH declaration of compliance. Such a statement can serve as a testimony to the authorities or as communication to customers and other stakeholders to show that your company is indeed REACH compliant in all the relevant aspects of the REACH Regulation. Such a statement is a hard asset outside of Europe as well.

A shift in focus towards formulators

As the burden of REACH has previously been mainly on substance manufacturers and EU importers, the focus of the regulation is now shifting towards formulators. The safe use of mixtures is a topic that will need to be addressed by operators in the coming years in the form of unique formula identifiers (UFI) and poison centre notifications (PCN). This will require a thorough knowledge of the composition and hazardous properties of the supplied mixtures as well. Exposure scenarios and their utilization in communicating the safe use of mixtures will surely be giving formulators some gray hair.

Increasing amount of regulation

As ECHA is now the holder of the world’s largest open database of substance information, plans on how to best utilize the gathered information on the registered substances are big. On a general level this might mean more substance restrictions and harmonized classifications. Manufacturers of highly hazardous substances or those who have submitted incomplete information, on the other hand, might become a target for even more scrutiny.

Reaching the legislative deadline will also most definitely result in increased supervision from national authorities on whether or not companies have fulfilled their various requirements under the REACH Regulation, with regard to substance restrictions and registrations especially. A more scrutinized assessment of SDS’s and of the responsibilities that downstream users have regarding exposure scenarios and their assessment against their own conditions could also result.

Harmonized classifications under the CLP Regulation ((EC) No 1272/2008) themselves can also be a source of restriction, as is now happening with titanium dioxide. A common chemical used as a pigment and thickener in a wide variety of applications for consumer use, including foodstuff, is about to receive a category 2 carcinogen classification, meaning heavy restrictions on its use in many of its current applications.

Competitive edge for European companies

One of the main original aims and visions of the comprehensive chemical legislation that is REACH is to ensure a high level of health and environmental protection. Another aim of the regulation has been to stimulate innovation and enhance the competitiveness of European brands on international markets. As chemical legislation is getting stricter all around the globe, REACH is indeed serving as an important example for other countries striving for increased chemical safety. This is one of the reasons why being REACH compliant is an asset all over the world; still today, REACH is the most advanced chemical legislation in the world.

Consumer image – a threat or a possibility?

An increasing amount of portals and sources for consumers on how to use chemicals safely and on how to find relevant safety information on chemicals have also emerged. Whilst a huge amount of scientifically-based information on chemicals and their safe use is now publicly available, what should never be underestimated is the opinion and views of the general public. Companies should therefore have an understanding of what the data gathered by them actually means and how it can be translated into facts and to transparent stakeholder communication.

Registration in the future

Now that all the three major deadlines for the REACH registration of chemicals in different tonnage bands have passed, the registration of future substances will require more planning in advance; as of now substances will need to be registered before manufactured or imported into the EU in amounts above 1 tonne per year. Make sure to make use of all the relevant exemptions to registration requirements. For R&D substances, for example, a PPORD notification will give your company a 5-year period of reflection before deciding on whether to continue with the substance or not. For substances produced in circular economy processes, further exemptions also apply.

For more of the concrete results that REACH keeps delivering, see the press release of the European Commission on the matter: http://europa.eu/rapid/press-release_IP-18-1362_en.htm

Leea Ojala, Senior consultant

20.6.2018, Helsinki

In case you have any questions about your obligations under the REACH Regulation or are interested in a REACH Declaration of Compliance or a screening of substance restrictions on your chemicals, contact Ecobio’s experts at: info@ecobio.fi or tel. +358 20 756 9450.

May 4, 2018

How to REACH the registration deadline by May 31st?

The REACH registration deadline is getting closer. Only a few weeks to go! ECHA has already received close to 22 000 registration dossiers. The most registrations have been filed from Germany, the United Kingdom and France. Here are a few tips for you regarding the approaching deadline:

Are you the lead registrant in a joint registration?

You should create a joint submission in REACH-IT by 9^th May at the latest.
Continuously communicate your progress to the other members of the SIEF. They will have to meet the registration deadline and will want to know when they will be able to submit their company specific dossier.
Make sure that you have a transparent break-down of the costs for your Letter of Access (LoA) available in case the other SIEF members want to see it.

Are you a member in a joint registration?

You should submit your company specific dossier by the registration deadline.
Make sure that you initiate the process for purchasing the LoA early enough. Typically, you will receive a token for the LoA after all the transactions have been made.
Know what you pay for! Make sure you know what is included in your SIEF agreement (i.e. is the CSR part of the joint submission or not).

Are you a downstream user?

Ask your supplier for a REACH compliance declaration.
Make sure that all the substances you purchase have a proper registration number after the deadline.
A pre-registration number is not a proper registration number. All the registration numbers are recorded in ECHA’s substance information database. You can find them in the substance specific dossiers.
Know your obligations as a downstream user. Even though you don’t have to register, REACH still applies to you.

Contact Ecobio’s experts with any questions related to chemical legislation and the REACH Regulation. We are always happy to help.

For advice or for more information, you can contact us at info@ecobio.fi or tel. +358 20 756 9450.

Ecobio Manager – Regulation Tracking and Chemical Management Service

January 22, 2018

REACH 2018 Stakeholder’s Day – one week to go!

The European Chemicals Agency (ECHA) is organizing the REACH 2018 Stakeholders’ Day next week from 29 to 31 January in Helsinki. The conference offers hands-on training on different tools, such as Chesar, REACH-IT and IUCLID Cloud. In addition, the conference provides news and advice on the main issues companies are facing. The programme for the REACH 2018 Stakeholder’s Day:

Monday 29 January: hands-on training on Chesar, the chemical safety assessment and reporting tool
Tuesday 30 January: hand-on training on REACH-IT and IUCLID Cloud
Wednesday 31 January: conference

The most important theme of the conference is the 2018 REACH registration deadline, which is only in four months time. The conference presentations provide important advice on the registration, e.g. last-minute tips, how to get all of the data together and how to share costs. The conference is concluded with a panel discussion on what happens after the REACH 2018 deadline.

You can follow the conference live via web-streaming on 31 January and send questions online. More information and the full programme: https://echa.europa.eu/fi/-/reach-2018-stakeholders-day

Ecobio’s experts will be participating in the REACH Stakeholders’ Day. We are always happy to help with questions related to chemical legislation and the REACH Regulation. For advice or for more information, you can contact us at info@ecobio.fi or tel. +358 20 756 9450.

Ecobio Manager – Regulation Tracking and Chemical Management Service