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ECHA’s Biocides Stakeholder Day coming up

The European Chemicals Agency ECHA will be hosting the Biocides Day 2018 on the 24th and 25th of October in Helsinki, Finland. The stakeholder day will give insight into the latest developments in biocides at the EU level.

In the EU, the Biocidal Products Regulation (BPR) regulates the placing on the market and use of biocidal products. As a principle, biocidal active substances must be approved for use at Union level, and all biocidal products require an authorisation before they can be placed on the market. Product authorisations take place either at Member State level or as a Union authorization.

As active substances are increasingly being approved for use, the need for the authorization of the biocidal active products containing such active substances are becoming imminent. For example, the deadline for the product authorization application of sodium hypochlorite is already 1.1.2019.

The Biocides Day by ECHA will deal with e.g.
• tips for a successful Union authorisation
• best practices for a product family authorisation
• the impact of Brexit and
• the impact of endocrine disruptor criteria

You can join the day through ECHA’s webpages: https://echa.europa.eu/fi/-/biocides-day

Ecobio’s expert will also be present; you are more than welcome to ask us anything relating to chemical or biocides legislation! Contact us at info@ecobio.fi.

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.

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 9th 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

Californian Trend: Artificial Intelligence (AI) Tackles Energy Challenges

The Applied Artificial Intelligence Conference was held in San Francisco in April, 2018. The event chose to outline the key themes and potential challenges that are at the forefront of the artificial intelligence revolution. The revolution of our energy systems is one of the most impactful transformations of our time.

AI will shape the future of energy. It is a fact that globally our energy systems will change dramatically in the long run. Renewable energy production will be greatly expanded. Energy production will become decentralized and fragmented. Our homes and other forms of real estate will become both consumers and producers of energy simultaneously. Furthermore, the heating, cooling, lighting and security systems of our homes, offices and factories will be governed by smart devices connected to the energy grid.

The renewable energy system will need a high capacity of energy storage. This will mean the placing of both small and large batteries all around the energy grid. To manage this complicated system there will need to be a substantial collecting, handling and operating capacity for the vast amount of data and processes involved. Without the efficiency created through artificial intelligence, this change would not be possible.

Artificial Intelligence will help us manage environmental problems, too. In Ecobio, we re-imagine your environmental and health & safety management processes. We strive towards constant modernization of our services and provide you as our customer with the most advanced solutions. The Ecobio Manager regulation tracking and chemical database service is our flagship innovation. It helps you focus on more complex problems by automating your compliance tasks.

Are you aware of the corporate sustainability challenges that need to be solved. Please contact our development team: sanna.perkio@ecobio.fi.

Blog: Solar energy production demands both solar power and space to utilize it

Land availability is a limiting factor in the implementation of both solar and wind farms; as Richard Lancaster, CEO of CLP Holdings Limited pointed out in his lecture held at Stanford University. Richard himself, being a leader of a large energy company in Asia.

Renewable energy has paradoxes

Big cities are the largest consumers of energy, although they do not have the free land necessary to utilize renewable energy production. Where the strongest winds occur, no one lives. More space is needed in the production of wind power than solar power. In regions such as Silicon Valley, which holds a large volume of roof area along with enjoying a large amount of sun shine; there are advantages in utilizing solar powered energy production.

Whilst discussing an innovation concerning efficient land use, Richard also mentioned a successful project in which they connected solar production with culturing cultivating honeysuckle in the desert.  They collaborated with a local community of farmers in doing so. It was a win, win situation for all parties concerned: the energy producer, the farmers and the regional government.

Sanna Perkiö, 03/05/2018, Stanford