REACH 2018 and after
19 April 2018
CLEPA Materials Regulations Event
Monique Pillet
Scientific Officer
• Many more registrations
• Less companies registering the same substance
• Higher % of SMEs
• Less information need to generate new data
What do we expect?
2017 2018 2019
3 Sep1 Jun
Deadline
Extended processing time
(3 months from deadline)
1 April
60 000 Dossiers (estimate)
20 000 Substances (estimate)
Normal Completeness Check
Until 1 April (21 days)
150 dossiers/week
350 dossiers/week
Number of dossiers
received
Deadline completed
>8000 dossiers/week
250 dossiers/week
9th April:
21 170 Regs
7 863 Subs
What do we expect?
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REACH 2018 snapshot
• 21 170 registrations received for 7 863 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 9th April 2018
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Need support?
REACH 2018 webpagehttps://echa.europa.eu/reach-2018
Contact your national helpdeskhttps://echa.europa.eu/support/helpdesks/
Contact ECHAhttps://echa.europa.eu/contact
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Helping companies in exceptional situations
Further information and instructions at: echa.europa.eu/about-us/partners-and-networks/directors-contact-group
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
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Communication in the supply chain
Upstream Downstream
Informationon uses
Informationon safe use
Manufacturer Importers
Formulator
Formulator
End user
Users of articles
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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
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Working together on solutions
Suite of tools for improving communication in the supply chain
Key actors involved DUCC/Cefic/Concawe/Eurometaux/ECHA
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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
https://echa.europa.eu/about-us/exchange-network-on-exposure-scenarios
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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
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Articles can be assembled…
…to become a “complex object”
Mixture M
mechanically or using a substance/mixture
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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
https://echa.europa.eu/regulations/reach/candidate-list-substances-in-articles
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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 2019
3. Revision of Waste framework directive
• DB on SVHC in articles, including at waste stage
Key messages
2018 deadline is one step
→ REACH journey continues
Communication in the supply chainis a key pillar of REACH
→ contribute to it
Substances in articles
→ ensure safety to users of
articles