Sharing of Inorganic Compound Registration Strategies

With the wide application of chemical substances, the targets of new chemical substance registrations in China have also been expanding. In recent years, REACH24H has undertaken a number of inorganic substance registration projects. Inorganic substance is the abbreviation for inorganic compounds, which refers to all elementary substances and compounds with the exception of organic carbon (containing carbon-based substances). The vast majority of inorganic substances can be grouped into the four categories of oxides, acids, bases and salts. Due to the particular qualities of inorganic substances, physic-chemical and eco-toxicological data exemptions apply. The physical and chemical properties of the flashpoint, the partition coefficient(n-octanol/water), the stability in organic solvents and the characteristics of degradation products, as well as biodegradability in eco-toxicological data all point to clear descriptions of the inorganic compound which can be exempted. In terms of the qualitative analysis of substances, inorganic substances also have their particularity compared to organic…

Mar. 24th, 2020

New Requirements for Nanomaterials under EU REACH

With the rapid development of nanotechnology, nanomaterials are now widely used across many fields. At present, the most commonly used nano-materials for industrial purposes in Europe are silicon dioxide, titanium dioxide, carbon nanotubes, carbon black, and etc. According to scientific studies, the toxicity of nano-form substances and their impact on the human environment may differ from traditional substances. Therefore, since 2012, ECHA has established a Nano Expert Panel (ECHA-NMEG) to study and formulate the registration requirements and scientific as well as technical guidelines for nanomaterials under EU REACH regulations. In December 2018, the European Commission issued a REACH Regulation Amendment (Commission Regulation (EU)2018/1881), which proposed new regulatory requirements for nanomaterials to ensure that enterprises can provide enough information for the safe use of nanomaterials. The amendment will officially be implemented on January 1, 2020. This means enterprises that have completed registration of nanomaterials will have to update their dossiers according…

Mar. 24th, 2020

How to Protect Your EU REACH Registration Number?

The registration number is a necessary condition for enterprises to enter the EU market, and it’s very difficult to distinguish whether the registration number is true or not in the industry sometimes. Generally, importers with strong compliance awareness will actively contact their only representative (OR) to confirm the authenticity of the REACH document. REACH24H also received many inquiries from importers, and in the process of authenticity on registration number, we deed identified a number of “forged” documents. Among the most common compliance documents, Confirmation Letter of REACH Registration, Submission Report, and REACH Compliance Import Certificate are the most frequently forged. Even importers have repeatedly received tampered REACH documents. REACH24H’s RSCC system is a platform designed to help enterprises meet the requirements of REACH regulations. Its principles can be summarized as follows: OR does not recognize the information confirmed by non-trade parties; OR will not be responsible for the records generated…

Mar. 24th, 2020

Japan Works out Draft Adjustment to Subject Substances under PRTR

According to the proceedings of an internal meeting held by Japanese authorities on February 19, 2020, the government has worked out a draft adjustment to the lists of substances subject to the Pollutant Release and Transfer Register (PRTR) law. Under the PRTR system, currently, 462 substances are designated as Class 1 substances and 100 other substances as Class 2 substances. Businesses handling Class 1 substances are required to estimate and report the release and transfer of such substances on a regular basis. Both Class 1 and 2 substances are subject to SDS and labeling requirements under the GHS framework. The draft adjustment proposed to increase the number of Class 1 substances and Class 2 substances from 462 to 527 and from 100 to 137. Especially, 271 substances will be newly added and 169 will be removed from the existing lists. But it should be noted that this draft adjustment is…

Mar. 06th, 2020

EU REACH, Moving from Registration to Evaluation

One year has passed since the last deadline for EU REACH registration, and in 2019 ECHA gradually shift their focus to the second phase–Evaluation. For enterprises, there are still issues to participate after completion of registration. Some luckily received a refund of LOA fee, while others were required to pay additional fees for supplementary experiments. According to ECHA’s work plan, the evaluation of all registered substances will last until 2027. Therefore, chemical companies that trade with Europe will not only have to transfer their registration numbers carefully to ensure the safe passage across the supply chain but also have to determine their product life cycle based on the evaluation data and carry out product upgrades complying with green and environmentally sustainable standards. Because in the long run, only green and environmentally friendly products will manage to remain competitive. Compliance Review 2019 EU REACH: ECHA Has Been Shifting The Focus to…

Mar. 05th, 2020

2019 Compliance Review: Chemical Safety and Environmental Protection Policy in China

In recent years, corporate safety and environmental protection policies are constantly being updated, following changes and shifts in government regulations and approaches. A highly relevant part of any compliance work relies in an enterprise’s ability to timely capture compliance points and accurately adapt in accordance with policy trends. Looking back this year, safety supervision has become closely centered on the theme of “preventing risks, removing hidden dangers, and containing accidents”, highlighting the safety focus ofhazardous chemicals, and aiming to prevent and resolve safety risks, promptly eliminate hidden dangers, and effectively contain safety accidents as the goal of production safety, as well as develop a series of activities including public and educational material, emergency drills, and safety inspections. Environmental protection management and control revolve around the four major  tasks of water conservancy, soil and gas control, and solid waste management to fight pollution and further promote the ultra-low emission transformation of…

Mar. 01st, 2020

Sharing of Inorganic Compound Registration Strategies

With the wide application of chemical substances, the targets of new chemical substance registrations in China have also been expanding. In recent years, REACH24H has undertaken a number of inorganic substance registration projects. Inorganic substance is the abbreviation for inorganic compounds, which refers to all elementary substances and compounds with the exception of organic carbon (containing carbon-based substances). The vast majority of inorganic substances can be grouped into the four categories of oxides, acids, bases and salts. Due to the particular qualities of inorganic substances, physic-chemical and eco-toxicological data exemptions apply. The physical and chemical properties of the flash point, the partition coefficient(n-octanol/water), the stability in organic solvents and the characteristics of degradation products, as well as the biodegradability in eco-toxicological data all point to clear descriptions of the inorganic compound which can be exempted. In terms of the qualitative analysis of substances, inorganic substances also have their particularity compared…

Mar. 01st, 2020

2019 Compliance Review: China New Chemical Substance Notification

The Measures on the Environmental Management of New Chemical Substances (MEP Order No.7) has entered its 10th year since its promulgation. This year brought along key changes on the MEP Order No.7, in January, Ministry of Ecology and Environment (MEE) published the Environmental Risk Assessment and Control Regulation for Chemical Substances (Consultative Draft), which means that China will not only manage new chemical substances in the future but will move in a new direction to manage all chemical substances. In July, MEE published the draft revision of the Measures on the Environmental Management of New Chemical Substances. At the end of November, three Chinese companies were fined for manufactured new chemical substances without notification, which is a signal that regulatory enforcement will be enhanced and we will see more supervisory activities. •  On January 8th, 2019, MEE published the Environmental Risk Assessment and Control Regulation for Chemical Substances (Consultative Draft)…

Mar. 01st, 2020

2019 Compliance Review: K-REACH Updates

The Act on Registration and Evaluation of Chemicals , hereinafter referred to as K-REACH, has been implemented for five years. It is another international influential chemical regulation act after EU REACH. The implementation of K-REACH has a huge influence on global chemical industry. The management method of K-REACH is quite similar with EU-REACH, such as the registration, evaluation, authorization and restriction of chemicals and downstream products. For chemical suppliers outside Korea, they need to complete the registration through the only representative (OR) in Korea. On January 1, 2019, the new version of K-REACH was officially implemented, which comprehensively revised the implementation of the regulations, expanded the number of registered substances, introduced pre-registration, and increased penalties. A series of new measures have strengthened the management of high-tonnage and hazardous chemicals, and have reduce requirements for low-risk, low-tonnage materials. Compliance Review Notification of CMR List and Priority Substance Chemicals、Exemption Substance List Published…

Feb. 29th, 2020

When is the Good Time to Join CICO after Pre-registration?

According to Article 10 (3) of K-REACH, pre-registration and Late pre-registration are required in order to have access to a grace period –so long as enterprises manufacture or import more than one ton of existing chemical substances per year. For enterprises that wish to register the same substance, it is necessary to join CICO first and then establish a “consortium” to prepare for joint registration during the grace period. In CICO, companies can play three roles: lead registrant, active Lead Registrant (LR), Active Member (AM) and Passive Member (PM) are the three roles in CICO, all bearing different responsibilities and burdens. The LR is the leader of the joint-registration and the AM plays the role of main supporter for the LR. These two roles are jointly responsible for the operation of CICO, formulating cost sharing rules, preparing the registration dossier and paying the early data testing costs. PM are charged…

Feb. 29th, 2020
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