Tag Archives: REACH

RoHS Recast — Regulatory Update Made Official

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The Council of the European Union (“the Council“) officially revised the RoHS directive on hazardous substances in electrical and electronic equipment.  The chemical restrictions will now apply to all electrical and electronic equipment, as well as to cables and spare parts, and to medical devices, medical equipment, control and monitoring equipment – which were previously exempt from RoHS compliance but are not exempt now.

Further, this recast will harmonize the directive across the European Union.

The product categories affected by RoHS include large household appliances, computer equipment, TVs, lighting, toys and video games, and vending and ATM machines – as well as the categories listed at the top of this article.  You can imagine then that almost all discrete manufacturing sectors are affected – as most use computer equipment in parts, components or assemblies.  RoHS creates a notable data management challenge in terms of supplied parts and compliance certification.

RoHS Recast provisions. Provisions are included in the recast to allow time for the market to adjust.

A three-year transitional period is allowed for some devices:

  • monitoring
  • control
  • medical

A five-year transitional period is allowed for:

  • in vitro medical devices

A six-year transitional period is allowed for:

  • industrial control appliances

Nanomaterials under RoHS. Everyone wants to know how nanomaterials will be regulated.  It’s a grey area.  Rightly, the European Commission says that work towards a common definition of nanomaterials is necessary (yes!) and ongoing. The EC intends to adopt a Commission Recommendation on a common definition “in the near future.”

The Commission considers that the RoHS provisions cover different forms (including nanoforms) of the substances which are currently banned. The Commission also considers that these RoHS provisions cover forms subject to a priority review under RoHS in the future.

RoHS Recast next steps. Next steps include:

  • Signatures and Journal publication
  • Transposition into EU member state laws
  • Industry implementation

There are a few good resources for more information. Design Chain Associates (DCA) has a good article and some (reasonably priced) on-demand webinars for more in depth review.

Would you accept this RoHS? It may be a good idea to review why we are gathered here today. While the ins and outs of regulations can be like jungle hacking – a look from the air is a good idea from time to time.

There are measurable environmental benefits to a well-executed and enforced RoHS program. Reported environmental benefits include:
•    reduction of lead (Pb) use in products by 82,700 tons in the EU
•    reduction of cadmium (Cd) use in products by 14,200 tons
•    reduction of mercury (Hg) use in products by 9,500 tons due to changes in copiers and fluorescent light bulbs
•    reduction of mercury in waste streams by 6,900 tons

RoHS restricted substances. RoHS focuses on six hazardous substances: lead, mercury, cadmium, hexavalent chromium and two types of flame retardants in plastics (PBB and PBDE). The restrictions have not changed since last November, but additional hazardous substances are now expected, whereas the list of substances of concern under the previous version of RoHS was considered more stable. Click here for the current list/threshold amounts.

To wit, RoHS is a directive, not a regulation. The difference is that a directive cares only about the result. With RoHS, for example, the required result is the restricted use of certain toxic metals in electronics manufacturing. A regulation, on the other hand, delineates to each entity under the umbrella of the regulation how to get the result.  A good example is the REACH regulation, which has a detailed process for substance registration, use, and data sharing.

ECHA to Add 7 Chemicals to REACH SVHC List

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The European Chemicals Agency (ECHA) will shortly add seven new chemical-substances to REACH regulation’s Candidate List of Substances of Very High Concern (SVHC). The comment period was slated to last through July 4, but ECHA says that the consultation period is now over.

The seven candidates for SVHC are as follows:

  1. 2-ethoxyethyl acetate
  2. strontium chromate
  3. 1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters
  4. Hydrazine
  5. 1-methyl-2-pyrrolidone
  6. 1,2,3-trichloropropane
  7. 1,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters, C7-rich
  8. Cobalt dichloride

The list shows eight substances because it includes cobalt dichloride. The status of cobalt dichloride is actually up for re-evaluation, due to its revised classification as both carcinogenic and toxic for reproduction. Cobalt chloride was originally identified in October 2008 as SVHC solely on its carcinogenic properties, says REACHtracker.

REACH update

The Candidate List is growing. There are now 46 SVHCs. The next ECHA consultation is planned for August, and that will kick off a busy time as the European Commission expects to have reviewed and listed 135 SVHCs by the end of 2012. The goal is to have reviewed, listed and regulated all relevant known SVHCs by 2020.

In the meantime, expect bi-annual updates to the Candidate List.

Further reading

For more on these chemicals, see Chemical Watch (pay site).

For detail on each chemical, here’s a good page from Safe Packaging.

The Actio chemical databases will be updated to reflect the change as soon as the Candidate List is updated; for now these chemicals are flagged as “probable SVHCs.” Wishing you good luck with quality assurance efforts and product development in this era of digital chemical management. It’s not easy!

Useful Web Page for REACH Compliance

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ECHA CHEM is a web page on the ECHA web site, itself notoriously difficult to navigate. However, it must be said that improvements are appearing. The ECHA CHEM page is nearly comprehensible!  While intuitive may still be some ways off, at least extracting information about REACH on this page is not painful. For readers interested in REACH news and REACH compliance tools, we are running this breakdown.

ECHA CHEM in a nutshell. The REACH Regulation (or REACH pandemic?) provides that various types of information submitted to ECHA or documents that are produced as an outcome of different REACH processes are to be published on the ECHA website. Under the ECHA CHEM web section you will find public information and documents from REACH processes as they become available.

Registry of intentions. This Registry provides information on the Intentions of the Member States to submit proposals for harmonised Classification and Labelling of substances, proposals for identification of Substances of Very High Concern, and proposals for restrictions.

List of pre-registered substances. The REACH Regulation requires that ECHA will publish by Jan. 1, 2009, a list of substances which have been preregistered between June 1 and Dec. 1, 2008.

Authorisation. The two first steps of the authorisation procedure are the identification and inclusion in the “Candidate List” of Substances of Very High Concern, and the prioritisation of substances to be included in Annex XIV of REACH (the “Authorisation List “).

Candidate List of Substances of Very High Concern for Authorisation. In the framework of the authorisation process, Member States Competent Authorities or the ECHA, on a request by the Commission, may prepare Annex XV dossiers for the identification of substances of very high concern. The outcome of this identification procedure is a list of substances (“the Candidate List”), which are candidates for eventual inclusion in the List of Substances Subject to Authorisation (Annex XIV of REACH).

Annex XIV recommendations. The REACH Regulation requires that ECHA identifies from the “Candidate List” priority substances to be included in Annex XIV of REACH (the “Authorisation List”) and then recommends Annex XIV entries for these substances to the European Commission. ECHA submitted its first recommendation to the European Commission on June 1, 2009.

Information from registration dossiers. ECHA is publishing information on substances and their properties from the registration dossiers submitted to ECHA.

Transitional measures regarding existing substances. The REACH Regulation provides transitional measures for certain existing substances under Regulation (EEC) No 793/93. These substances were prioritized due to being produced in large quantities or having possible persistent, bioaccumulative and toxic properties.

ECHA publishes the Annex XV transitional reports on priority substances submitted by the EU Member States. For some substances, manufacturers and importers need to submit additional information to the Member State Competent Authority in charge. Updated assessments and so-called “voluntary risk assessment reports” will also be published there.

See it all:  http://echa.europa.eu/chem_data_en.asp

Cadmium Banned in Europe in November

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The European Commission announced May 20 that the European Union will ban cadmium in jewelry, brazing sticks and plastics beginning this November. A Commission press release states that the new legislation, which will be adopted as an amendment under the EU’s Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation, will prohibit the use of cadmium in all types of jewelry products, except antiques; brazing sticks, which are used to join dissimilar materials; and — in theory — all plastics.  

We say “in theory” in regards to the cadmium ban in “all plastics” because the Commission notice on the updated cadmium restriction appears to have inconsistencies regarding plastics.

The notice on World Trade Interactive suggests that cadmium will be banned in all plastics (with the exception of some recycled PVC).  But an article in British Plastics & Rubber points out semantic oddities in the Commission’s draft document.

The draft references the proposed amendment to Restriction 23 of Annex XVII, which covers cadmium and its compounds.  However, the Commission’s report contained no changes from the 2010 document regarding the list of materials that would be affected.  The wording of the recent statement says “all plastics” would be affected by the ban, but the itemized list of named plastics remains the same.

This leaves the door open for some agents to interpret that plastics not itemized on the list are exempt.

This language snarl is worth being aware of.  In the long view however, while it may delay a revision, it likely won’t stop the fact that cadmium use in virtually “all plastics” will be banned in the EU either in Q4 of this year or shortly thereafter.

And that, of course, is the “heads up.”  (For more on the language snarl, see article, Cadmium — banned or not?)

Cadmium backstory. Cadmium has many uses. It’s used in paint as a pigment, for starters. Or was. EPA and regulatory bodies around the world have been trying to restrict or prohibit cadmium use in paint for years. Often trace amounts of cadmium result in public-perception denigration and expensive product recalls that affect the bottom line; such events are arguably more of a deterrent for industry than the anti-cadmium regulations themselves.

Last summer, for instance, REACH compliance watchdogs found traces of cadmium in Shrek glasses for children. The glasses were manufactured to be sold at McDonald’s as part of the Shrek film promotion. McDonald’s had to recall over 12 million of the glasses that would have retailed for $2 each; that’s a loss of $24 million, plus the operational costs of the recall.

Many think recall events due to substances like cadmium are primarily a supply chain communication failure. While that is true, recalls also point to a regulatory gap and a supply chain that quite naturally tries to cut corners.

The EU appears to be ready to send a clear message:  no cadmium. And to many manufacturers — although probably not to the manufacturers of cadmium pigment — a clear regulation is a welcome regulation. Last year, EPA moved on this item as well when cadmium turned up in kids’ jewelry.

Cadmium alternatives. There’s no reason we need to be using cadmium in this day and age, right?  Problem is, especially for industrial uses, cadmium is very effective as a plating over steel as it’s remarkably resistant to corrosion.

A cadmium alternative for components must be, among other things:

  1. A panacea: act as a general corrosion coating for all seasons
  2. Specific protection: provide good salt spray and scribed corrosion protection
  3. Non-crackable case: cannot succumb to hydrogen embrittlement or stress corrosion cracking.

As a coating, the cadmium alternatives must, among other things:

  1. Retain thread profile/detail underneath, especially in jewelry
  2. Be solderable
  3. Be usable in electrical equipment in terms of conductivity and heat-effect limits.

At minerals.usgs.gov, the government says that coatings of zinc or vapor-deposited aluminum can substitute for cadmium in plating applications.

In 2002, a group published an evaluation of cadmium replacement alternatives for aircraft with notable results. Typically aircraft are exempt from cadmium legislation because of a “no known alternative” clause. In other words, nothing works as well so it is allowed for now.

This still creates a cost and a wrench in manufacturing process, however, due primarily to the problem of disposal of this known-toxic material at end-of-life. Where does cadmium go to die? We’ve all heard of the aircraft boneyard.  Aircraft manufacturers are responsible for end of life disposal of all parts and components (and substances).  The costs associated with end-of-life makes alternatives to cadmium look better and better.  For more on aircraft and replacements, see the Rowan Technology Group 2002 report on cadmium replacements.  It’s an interesting document.  Spoiler alert:  the report concludes that aluminum (Al) is the best cadmium replacement for uses in aerospace, automotive and electronic components in terms of behaving most like cadmium.

The point is that there are alternatives to cadmium — depending on application. For the most part, the replacements are sister- or cousin-metals.

For more on the cadmium ban coming in November under REACH regulation, review the European Commission’s press release.  Also, keep an eye on this blog as we’ll keep you posted on the critical cadmium (and similar) regulatory update status as we go through 2011.

REACH Penalties: Belgium Found Guilty

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Belgium is the first EU Member State to be condemned by European Court of Justice for breach of REACH.  This is the result of a May 5 judgment in Case 265/10 Commission vs. Belgium.

REACH has been very clear from the beginning that Member States have their own responsibilities and their own penalty structures.  For instance, the chart (above) shows comparative REACH compliance fines between countries across Europe.  Belgium has among the highest penalties in the EU.  Moreover, the chart shows the incredible discrepancies between how Member States choose to implement and moderate REACH compliance.  (The chart is from the EC December report on penalties, from a study conducted by Milieu Ltd. for the European Commission.)

Brussels fails to comply. REACH Article 126 imposes the obligation on EU Member States to adopt whatever measures necessary to ensure sufficient and correct enforcement of REACH.  Crucially, EU Member States were obligated to notify their enforcement/sanctions-systems to the Commission by Dec. 1, 2008.

Brussels-based Peter Kugel, Partner at Kugel Legal, a firm specializing in EU Law & Litigation, reports that “Belgium evidently failed to comply with that obligation because the Regions of Wallonia and Brussels-capital had not yet adopted any measures to comply with Article 126 REACH.”

REACH “cooperation agreement.” The Commission argued that Belgium failed to comply with Article 126 because there was no “cooperation agreement” in place between the Federal Government and the Regional governments.  A “cooperation agreement” would be an agreement that paves the way for cooperation between the different inspection services in a Member State, largely by implementing modalities of cooperation and information exchange pathways.

The Court dismissed the argument that lack of such an agreement would necessarily lead to lack of compliance.

The court found that, yes, such an agreement could certainly be an appropriate instrument towards the implementation of an effective sanctions-system in connection with violations of REACH (as foreseen by Article 126).

“However,” points out Kugel, “the Court ruled that neither Article 126 REACH nor any other provision of REACH oblige Member States to engage in such domestic ‘cooperation agreements’ for a correct implementation of Article 126 REACH.”

In other words:  it’s each country’s responsibility to figure out its compliance infrastructrue.  It is not up to any outside (federal) agent to coordinate or install procedures to ensure clear compliance processes for a Member State.

REACH breach ruling insight. Many were surprised that Belgium was the first to receive a judgement against their REACH compliance efforts.

Politically, in the longer term, to crack down on Belgium first could be a smart decision.  It shows lack of favoritism when it comes to compliance breach judgements.  In the short term, though, Belgium comes away with a bruised ego and a bruised Public Relations team.  Overall?  It’s nothing a month or two and a few more condemnations in other directions won’t fix.

In saying that, however, we must not be glib.  Businesses in America are watching compliance rulings on REACH like hawks.  Rightly so.  As court action heats up, so will fines, and then all import/export companies will really begin take REACH compliance risk management more seriously.

Apparently, and refreshingly perhaps, the “we didn’t know how to do it; we didn’t know what was going on” argument isn’t flying far in European courts.

Top 5 Questions About RoHS in 2011

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Here are the top 5 things businesses need to know about RoHS in 2011.  And first, an overview of the RoHS directive.

RoHS overview

As of July 1, 2006, producers and importers of electrical and electronic equipment (EEE) in the European Union (EU) must adhere to the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations (RoHS).

RoHS is a directive, not a regulation.  The difference is that a directive cares only about the result.  With RoHS, for example, the required result is the restricted use of certain toxic chemicals in electronics manufacturing.  How businesses achieve that result, or how member states handle governing that process, is up to each.

A regulation, on the other hand, delineates to each affected entity how to manage compliance with the law.  A good example of a regulation is the REACH regulation, which has a detailed process for substance registration, use, and data sharing.

RoHS restricts — and in some cases bans — the use of certain hazardous substances above a specified amount in the manufacture of electronics.  The key hazardous substances under RoHS are lead, cadmium, mercury, hexavalent chromium, as well as polybrominated biphenyl (PBB) and  polybrominated  diphenyl ether (PBDE) flame retardants.  Part of the RoHS objective is to prevent thousands of tons of banned substances from being improperly disposed of, thus protecting human health as well as the environment.

As of November of 2010, there was an update to RoHS called the 2010 RoHS Recast.  The restriction updates are best depicted in a table:

The product categories effected by RoHS include large household appliances, computer equipment, TVs, lighting, toys and video games, and vending and ATM machines. Two categories – medical devices and equipment and control and monitoring equipment – are currently exempt from RoHS compliance.  More details about effected and RoHS exemptions and categories can be found on the UK RoHS website.

Producers must now prepare documentation to show that their products are compliant before placing them on the market, and, if requested, provide the documentation to the RoHS Enforcement Authority within 28 days. Also, this documentation must be maintained for four years after the product is no longer made available on the market.

The effect of RoHS has extended well beyond the EU. Major electronics manufacturers have adopted changes on a global scale in order to comply with RoHS, regardless of where their products are sold. As a result, companies that supply parts to these manufacturers must also track and maintain accurate information about these components.

1. What is the RoHS – REACH Connection? REACH regulations restrict the use of Substances of Very High Concern (SVHCs) in Europe and the importation of articles containing these substances from outside of Europe. RoHS complements REACH by limiting the amount of hazardous substances that can be used to produce EEE in Europe and defines the proper disposal of EEE waste.

2. Who is exempt from RoHS regulations? Private individuals making purchases from outside the European market are not required to comply with RoHS. Because the first importer of a product to the European market is responsible for complying with the regulations, businesses acquiring products from within Europe are also not required to comply.  Again, specifics about effected and exempt categories can be found on the RoHS website or in last year’s RoHS articles on the Actio Blog.

3. What are the costs and benefits of RoHS? According to the March, 2008 Final Report of the “Study of the RoHS and WEE Directives”, published by the environmental consulting firm Ecolas for the European Commission, RoHS has resulted in a major reduction of hazardous substances found in various products, reaping both environmental and economic benefits. You can view the report here.

Although RoHS presents many benefits, some of the costs associated with RoHS compliance have included R&D and capital costs, averaging 1.9% of annual revenues. For small and medium companies (SMEs), a consultancy called RSJ crunched the data and found the average cost of compliance for SMEs was as high as 5.2% of annual revenues.  That’s quite high.

Future and ongoing costs are estimated to the European Commission to average 0.4% of annual revenues.  These costs are due, in part, to increased administration and testing for compliance, the use of more expensive lead-free solder, the higher cost to manufacture lead-free components, and the lengthy exemption process.

4. Are there environmental benefits to RoHS? There are measurable environmental benefits to a well-executed and enforced RoHS program. Such environmental benefits include:

•    reduction of lead (Pb) use in products by 82,700 tons in the EU
•    reduction of cadmium (Cd) use in products by 14,200 tons
•    reduction of mercury (Hg) use in products by 9,500 tons due to changes in copiers and fluorescent light bulbs
•    reduction of mercury in waste streams by 6,900 tons

5. What are the big-picture benefits? Much analysis has been done leading to projections on the potential benefits of RoHS on a global scale.  Reports seems to show that primary benefits include:

•    increase of communication across the supply chain serves as a platform for the implementation of REACH and other initiatives
•    less leaching in landfills because WEEE contains less hazardous material
•    the use of lead-free solder increases the incentive to recycle because it contains silver and gold
•    the push for other countries and industries, such as aerospace and IT, to move to cleaner processes and reduced use of hazardous materials.

5 Case Studies on REACH Compliance

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For companies still wondering how their situation fits into REACH, the following case studies may help. These case studies address compliance in a variety of scenarios. The five instances of how-other-companies-did-it represent common situations. The case studies address both upstream and downstream scenarios.

1. Downstream user under REACH (with confidential uses)
A medium sized company supplying preparations to the marine sector consider implications of keeping this use of a substance confidential from their suppliers; find out what further action they may need to follow as a downstream user under REACH.

2. Global manufacturing company seeks to automate the collection of supplier data for REACH
A Fortune 500 manufacturer and retailer with operations worldwide seeks to automate supplier chemical data collection as much as possible for compliance with REACH.

3. AstraZeneca, a pharmaceutical manufacturer, and famous furniture company Herman Miller along with an automobile agency voice software testimonials on software products they use to manage substance-level compliance with substances under REACH and similar regulations.

4. An alloy producer (see also RoHS) clarifies duties under REACH
A producer of alloys determines that under REACH it is the component metals that constitute the alloys they manufacture that are within the scope of registration and for one of these that they import they will have registration obligations.

5. REACH and a company importing a solvent from the US
A company importing a solvent for the first time from outside the EU is concerned about having missed the preregistration deadline but finds they can pre-register and get help from other SIEF members.

These case studies — unless otherwise indicated and linked above — may be found on the web (at the time of this posting) at the following URL:  hse.gov.uk/reach/casestudies/index.htm.

European Agencies Ban Six Chemicals

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In REACH and chemicals news, it was announced in Europe that six dangerous substances are to be phased out. This means that manufacturers who use these chemicals in their products — or have absorbed them somewhere in their supply chain — will have to:

a) know about those offending product ingredients, and

b) find replacement raw materials if the company is to conduct business in Europe legally.

The Commission decision follows the successful first phase of REACH’s registration and notification of chemicals. It’s all a part of REACH, Europe’s initiative to make the use of chemicals safer.

European Commission Vice President Antonio Tajani said, “Today’s decision is an example of the successful implementation of REACH and of how sustainability can be combined with competitiveness. It will encourage industry to develop alternatives and foster innovation.”

What it means is that six substances of very high concern — also known as SVHCs — have been moved from the candidate list to the authorization list, known as Annex XIV, under the EU’s REACH regulation. Annex XIV is like chemical-Alcatraz, substances there cannot be placed on the market or used unless they get a special clearance from the Agency and authorisation is granted for a specific use. All SVHC listings, selections and classifications are based on recommendations made by the European Chemicals Agency (ECHA).

The following six chemical substances of very high concern are the first entrants in the Annex XIV:

1. 5-ter-butyl-2,4,6-trinito-m-xylene (musk xylene)

2. 4,4′-diaminodiphenylmethane (MDA)

3. hexabromocyclododecane (HBCDD)

4. bis(2-ethylexyl) phthalate (DEHP)

5. benzyl butyl phthalate (BBP)

6. dibutyl phthalate (DBP)

If your company uses any of these substances – even in tiny quanitites – or if these substances appear magically in your product from a mysterious supply chain source – a timetable for substitution will have to be submitted. These six substances have been determined to be either carcinogenic, toxic for reproduction or persistent in the environment and to accumulate in living organisms, and will be banned within the next three to five years.

Environment Commissioner Janez Potonik said: “Chemicals are everywhere in the modern world and some of them can be very dangerous. Today’s decision is an important step towards better protecting our health and the environment.”

Additional substances will be added to Annex XIV in the future.

The Commission also says it will put forth a greater number of known substances of very high concern for inclusion in the candidate list. The Commission and the European Chemicals Agency say they are fully committed to achieve this goal, and are expecting the “active engagement of the Member States.”

SVHC background. As we’ve reported previously in this blog, the SVHC list is simply a list of Substances of Very High Concern. “Only the European community could come up with such a tactful term for ‘highly toxic stuff,'” as a recent article in Environmental Leader put it.

By 2012, over 165 substances are expected to be listed on the SVHC candidate list. The list includes substances which are:

* Carcinogenic, Mutagenic or toxic to Reproduction

* Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB) (defined by REACH criteria), and/or

* Identified as causing probable serious effects to humans or the environment of an equivalent level of concern as those above, e.g. endocrine disrupters — for reference, in the US there are 134 suspected endocrine disruptors.

The latest SVHC candidate list is online here at the ECHA site, and if that site is down — as it often seems to be — go to the June 2010 SVHC candidate list hosted by Actio.

www.actio.net/default/index.cfm/actio-blog/

REACH’s Complete List of Registered Substances

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ECHA announced its list of publishable Phase-In substances under REACH regulation that were registered as of Jan. 24, 2011.

Every product is made from substances, and substances in some articles need to be registered with the European Chemicals Agency or ECHA if the products are intended to be brought to market.  Which products?  Almost any manufactured product that has a chemical in it:  clothing, furniture, plastic cases for electronic devices, motor vehicle parts, printed circuits, as well as process manufacturing products such as pharmaceutical drugs, solder and paint.

EU REACH regulation recognizes three primary deadlines for registering substances, see REACH timeline.  The first deadline was Nov. 30, 2010.  The next two deadlines are May 31, 2013, and May 31, 2018.  The deadline depends on the tonnage band and the hazardous properties of the substance.

About 30,000 substances are expected to be available in the database after expiry of the last registration deadline in 2018.  There are currently about 1/10th of that listed, just over 3000.  It’s expected that the number of substances listed in the database will increase over time, as we’ve said before, as companies will submit more registrations dossiers as we go.

List of REACH publishable Phase-In substances

Below is a preview of the list of publishable Phase-In substances under REACH regulation.  These were substances that were registered as of Jan. 24, 2011. ECHA has published this information on Registered Substances primarily so companies can start to use the data to bolster and gauge their own internal data processes and fortify their REACH software.  The information in the database was provided by companies in registration dossiers.

Please be aware that ECHA does not verify the information before dissemination, so some viewer discretion is advised.

Notice the bottom of the page says there are 62 pages of substances.  We won’t run them all here.  To see the full list, go to the ECHA database.

Please note that the ‘Registered As’ columns in the official ECHA published list (as above) are identified as follows:
•    FULL Indicates registration under REACH Article 10 as a full dossier
•    OSII Indicates registration under REACH Article 17 as an on-site isolated intermediate (OSII)
•   TII Indicates registration under REACH Article 18 as a transported isolated intermediate (TII)
•    ‘Yes’ Indicates the substance registration under REACH is complete
•    ‘In Proccess’ Indicates a dossier on the substance has been successfully submitted to ECHA and is being processed, i.e. the completeness check results are pending

As only publishable substances are listed, the list does not contain phase-in substances where the IUPAC name is claimed confidential under REACH Art 119(2)(g).  The list also doesn’t contain substances which are non-dangerous and not listed in EINECS.

A chemical named John Doe

If you want to keep your chemical name confidential in terms of ECHA registration, you must come up with an alias. As with most things REACH-related, there is a specific methodology for this.  You must provide an adequate public name as a precondition for the acceptance of a confidentiality claim for the chemical IUPAC name.

If ECHA rejects a confidentiality claim for the IUPAC name, the IUPAC name will be published. It’s best to take the time to create a public name the correct way.

The way to derive a public name for a substance are presented in the ECHA manual. There is a process for masking of various structural elements from the IUPAC name in order to derive a public name with just one level of masking. The one level of masking keeps it simple. If you feel your chemical needs additional levels of masking, a special request and allowance can in certain circumstances be made.

The full database contains a variety of information on the substances which companies manufacture or import: their hazardous properties, their classification and labeling and how to use the substances safely.

www.actio.net/default/index.cfm/actio-blog/

ECHA Enhances Enforcement of CLP

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On Jan. 25, some 29 countries from the European Economic Area sent 70 participants to ECHA  headquarters in Helsinki to strengthen the national harmonized enforcement of CLP, reports Chris Nowak of Actio, makers of chemical management software.

“The idea is,” Nowak explained, “that if ECHA takes the time to create skilled trainers, they will cascade their knowledge through training events in their own countries.

“We’ll see how it goes.  Both the enforcement of and penalties for REACH are somewhat episodic so far. Certainly well-trained inspectors are the cornerstone for the effective enforcement of CLP and REACH; but consistent legislative parameters would be helpful, too.  Surely we’ll be discussing this in some detail in Houston next month,” Nowak said.

CLP stands for the EU Classification, Labeling and Packaging Regulation.

Look forward to seeing how the “trickle down” enforcement works out for ECHA.  Enforcement has been a tricky aspect as the Agency charges forth in its admirable efforts to manage chemicals in the marketplace.

“We’ll see how it goes…”

www.actio.net/default/index.cfm/actio-blog/