ECHA Reminds Companies to Check the Credibility of the Lead Registrant before Accepting False Invitations

It is reported in the news released by ECHA on 22 February that some companies falsely claimed to be lead registrants (LR) for certain substances. Here REACH24H Consulting Group would like to kindly suggest that companies give a second thought to the credibility of the claimed LR. According to the core principle of “one substance, one registration” of EU REACH, the election and determination of LR must follow specific procedures. The claimed LR identity can be problematic in that the nomination might has not been agreed between the co-registrants, another lead registrant could have been selected or even a joint registration has been already submitted. If you are approached by such a company, you should not accept their offer to prepare a joint registration, but to look for the real lead and other registrants of your substance. For the invitation from a claimed LR, be it true or false, it…

Feb. 26th, 2016

ECHA Launched Public consultations on 27 Applications for Authorization

On 10 February 2016, the European Chemical Agency launched consultation on 27 applications for authorization covering 39 uses of the following 3 substances. The consultation period will expire on 6 April 2016. Any comments if available shall be submitted before that date. Substance Name Use Description Chromium VI compounds Used in surface treatment, hard and functional chrome plating, cooling systems, passivation of tin plates, production of copper foils, production of coloured stainless steel, and manufacture of sodium chlorate/chlorite. These uses take place in various industry sectors such as chemical industry, aerospace, automotive, electronics, lithography 1,2-dichloroethane (EDC) Used as solvent in the production of a polymer Diglyme Used as solvent in the manufacture of an active pharmaceutical ingredient More information is available on the ECHA Website. Chinese Version: ECHA就3类物质的27份授权申请开展公众咨询

Feb. 17th, 2016

ECHA Champions Joint Registration with a No to Individual Submission

On 6 January, the European Commission adopted a new implementing regulation to clarify the “fair, transparent and non-discriminatory” principles for data sharing under EU REACH, which came into force on 26 January, 2016. It gives ECHA the mandate to champion the “one substance, one registration” principle in the REACH regulation. To implement this requirement, the dossier submission tool REACH-IT had been adapted to reject submissions outside of a joint registration after a maintenance break before 27 January. This indicates that potential registrants are no longer entitled to submit dossiers individually even if a long-term negotiation was inevitable without a consensus in cost sharing. REACH24H advises potential registrants to get a good understanding of the registration status beforehand and pay attention to the following situations: • There can be two joint registration dossiers for one substance as a result of varied data requirements for differentiated uses as a substance or an…

Feb. 03rd, 2016

Registration is Not the End! REACH24H Elaborates on Compliance Strategies for REACH Compliance

The European Chemical Agency (ECHA) is expected to release the Annual Evaluation Report 2015 in the forthcoming February. In 2015, ECHA has adopted new strategies for dossier compliance check, with special attention paid to substances that exert the largest impact on environmental and human health. Given the increasingly frequent and strict evaluation activities taken by ECHA and its member states, REACH24H Consulting Group as the Only Representative (OR) of many non-EU companies has consistently represented the interests of our clients seeking for constructive communication with competent authorities and responded to multiple evaluation decisions and enforcement checks properly. It is worth noting that the post-registration compliance work can never be well accomplished without the cooperation of non-EU companies. In this article, REACH24H elaborates on ways for post registration compliance to address your concerns. 1. How to use the registration number by non-EU companies? Please visit our NEWRSCC compliance platform to download…

Jan. 26th, 2016

2015 Global Regulatory Highlights –Japan Chemical Regulations

The Japan Chemical Substances Control Law (CSCL) has imposed strict pre-marketing evaluation of chemical substances to prevent environmental pollution and control chemical risks to human health, plants and animals. The Law is intended to manage risks of industrial chemicals both manufactured in Japan and imported from abroad, giving the Ministry of Health, Labor and Welfare (MHLW), Ministry of Environment (MOE) and Ministry of Economy and Trade and Industry (METI) a broad regulatory authority. Here below is a summarized illustration of key development of Japan Chemical Regulations in 2015. Enacted on 16 April, 1974, the Japan CSCL was the world’s first to regulate chemicals and control risks. It has been amended 3 times in 1986, 2003 and 2009. The latest revised edition was issued on 20 May, 2009 and entered into implementation for two phases from 1 April, 2010 and 1 April, 2011 respectively. The Japan chemical regulatory system is very…

Jan. 14th, 2016

2015 Global Regulatory Highlights – Taiwan Chemical Regulations

The year 2015 witnessed new changes to the chemical substance management in Taiwan, with amendments made to the Toxic Chemical Substances Control Act (TCSCA) and the Occupational Safety and Health Act (OSHA). On 11 December, 2014, Taiwan’s Environmental Protection Agency (EPA) put into force the Regulation of New and Existing Chemical Substances Registration authorized by Article 7-1 of the TCSCA. On 1 January, 2015, Taiwan’s Ministry of Labor (MOL) put into force the Regulation of New Chemical Substances Registration based on Article 13 of the OSHA. To facilitate a good enforcement of these regulations, competent authorities in Taiwan took several moves to support the implementation of these regulations by releasing the updated Taiwan Existing Chemical Substance Inventory (TCSI) and the online submission system as well as launching the Phase I Registration. At such a time of bidding farewell to the past while ushering in the new, REACH24H Consulting Group helps…

Jan. 14th, 2016

2015 Global Regulatory Highlights – South Korea Chemical Regulations

The Act on Registration and Evaluation of Chemicals of Korea (a.k.a. “K-REACH”) is regarded as the first REACH-style chemical regulation adopted in an Asian country, which manages new chemical substances, existing chemical substances and downstream products by prescribing the requirements for registration, hazard evaluation and risk assessment. It was officially put into force on 1 January, 2015. After that the South Korean authorities took several moves to support its implementation by releasing the guidance documents, the on-line submission system and the 1st batch of 510 PEC substances that companies are most concerned with. At such a time of bidding farewell to the past while ushering in the new, REACH24H Consulting Group helps you connect the dots to grasp the highlights, well positioned to facilitate a comprehensive understanding of key developments of South Korea Chemical Regulations in 2015. South Korea is the 6th largest chemical trading nation, attracting many global corporations to…

Jan. 14th, 2016

2015 Global Regulatory Highlights – China Chemical Regulations

The year of 2015 is by no means an uneventful year for China’s chemical and environmental management. Work safety accidents occurred frequently, with the catastrophic Tianjin Blasts of 12 August attracting the most attention, igniting a huge public outcry for risk management of hazardous chemicals. More and more companies began to realize that there is no such thing as sustainable development without an environmental friendly chemical management. In the meantime, the Chinese authorities have stepped up efforts for intensified regulation, putting into effect the Inventory of Hazardous Chemicals (2015) on 1 May and its corresponding Implementation Guidance on 19 August as well as releasing the revised China New Chemical Substance Notification Guidance and the Measures for the Environmental Management Registration of Hazardous Chemicals on 25 June and 19 October respectively for public consultation. At such a time of bidding farewell to the past while ushering in the new, REACH24H Consulting…

Jan. 13th, 2016

2015 Global Regulatory Highlights – Global GHS

After the implementation of the UN GHS in 2003, many countries and regions worldwide followed suit. The year of 2015 witnessed a remarkable boom of GHS implementation worldwide. In the U.S., the revised Hazard Communication Standard (HCS) came into force on 1 June, 2015, requiring all the manufacturers, importers, distributors and end users in the supply chain to fulfill their due obligations for GHS compliance. In Canada, the final Hazardous Products Regulation (HPR) was issued on 11 February, 2015 and took effect from 1 June, 2015, demanding a full implementation of GHS in workplaces. In the EU, the Classification, Labeling and Packaging (CLP) Regulation became the only legislation to apply to the classification and labeling of both substances and mixtures from 1 June, 2015. Besides, the UN issued the 6th revised edition of GHS, with hazard classifications increased from 28 to 29 and desensitized explosives added to physical hazards. At…

Jan. 13th, 2016

2015 Global Regulatory Highlights – EU REACH

With the deepening of market globalization, trade barrier inevitably becomes a common phenomenon. In the chemical industry, the EU REACH regulation has long been perceived by many as a kind of technical trade barrier. Companies have learned a lot in their efforts for completing registration within the previous two grace periods for substances at tonnage band of over 1000 t/a or 100-1000 t/a. As the last deadline of 31 May, 2018 for REACH registration comes close, the European Chemicals Agency (ECHA) has taken several steps to facilitate joint registration before 2018. On the one hand, relevant provisions and data requirements have been updated. On the other hand, enforcement actions have been taken by ECHA to secure compliance in REACH registration, OR obligation, eSDS and risk management measures etc. At such a time of bidding farewell to the past while ushering in the new, REACH24H Consulting Group helps you connect the…

Jan. 13th, 2016
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