Life Cycle Thinking blog is moving.
I will continue to provide commentary about TSCA, REACH, product stewardship, sustainability, environmental marketing claims and more as part of the redesigned EHS Strategies, Inc. website.
Posted in Environmental Marketing Claims, Product Stewardship, REACH, Sustainability, TSCA, TSCA Reform, tagged EHS Strategies Inc., Environmental Marketing Claims, life cycle thinking, Product Stewardship, REACH, Sustainability, TSCA on March 22, 2013 | Leave a Comment »
ECHA reminds submitters to get in early for the second round of REACH applicable to manufacture or import between 100 – 1,000 metric tonnes/yr of a chemical substance not previously registered. The official deadline is May 31, but since many dossiers have been incomplete in the past, lead registrants are strongly advised to get their dossier in by March 31.
Reminder: Imported articles are exempt unless intended to release a chemical substance. (Notification, not registration, and customer communication can be triggered, regardless of volume, for articles with >0.1% Substances of Very High Concern.)
There are now 138 Substances of Very High Concern under REACH with the addition of another set of 54 chemicals December 19, 2012. Producers and importers of articles have 6 months to notify ECHA if articles contain more than 0..1% by weight and the use hasn’t already been registered.
Companies need to keep on top of new listings (about every 6 months) and be prepared to find out whether articles you make, sell or buy contain >0.1% adding to more than 1 metric tonne/yr. You can also see what’s likely to come up by looking at the list of “intentions” to add to the Candidate list here.
Also track whether any of the chemicals reach the “Authorization” (14 so far) stage that will restrict use.
EHS Strategies, Inc. can help you with the implications for your company.
“This is within the initial cost range for the whole of REACH, yet we have only passed through the first registration deadline. This points to two things: firstly, the costs are high; secondly, as smaller organizations enter the REACH processes we must find ways to eliminate all unnecessary costs. This can range from highlighting the big cost items and amending the legislation to simplifying the procedures at the implementation phase. Here, we look to the agency to review any activities which we’re not explicitly required by the legal text.”
Helpful webinar slides and audio have been posted on ECHA’s site regarding the CoRAP evaluation process on chemicals registered under REACH.
Presentations emphasize the tight time frame for the evaluations and the need to coordinate with fellow registrants so you have a central contact point (likely the lead registrant) to deal with issues around new testing and data submissions that may be raised by the evaluating member state. ECHA speakers reminded people that the listing on CoRAP does not mean there will be any change in current regulation of the chemical. Of course, time will tell.
See earlier blog here
For those of you who like to get ahead of official listings under REACH, ECHA has a posting of “intentions” to list new SVHC Candidates, proposed restrictions and classification and labeling harmonization proposals: http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/registry-of-intentions
Also be aware that there’s also a push to really up the number of SVHC by the end of the year (to 136 from the current 84).
ECHA’s Registered Substances Database contains 7,530 unique substances with information from over 30,000 dossiers.
A little under 3,000 chemicals have been identified as “intended” to be registered with the next deadline of May 31, 2013, for chemicals in the 100 – 1000 metric tonnes range.