REACH 2018 and after

19 April 2018

CLEPA Materials Regulations Event

Monique Pillet

Scientific Officer

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Overview

REACH 2018

Communication in supply chain

Substances in articles

• 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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Follow the progress

echa.europa.eu/registration-statistics-infograph#

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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

Thank you!

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monique.pillet(at)echa.europa.eu