Chemical compliance… what’s happening?

What’s happening with regard to chemical regulations internationally? Here are some updates we’ve prepared for you for February 2021.

Transfer REACH registrations by end of March

As of 31 December 2020, 80% of the 2,140 REACH registrants in the United Kingdom had completed or at least started the process of transferring their registrations to the European Union, according to data from the European Chemicals Agency (ECHA).

Companies that have not yet completed the transfer are urged to do so by 31 March 2021. Otherwise their registration will be revoked, and they will no longer be able to legally place their substances on the EU market.

More than 2,900 UK registrations have already been considered void and will be revoked, as they did not begin the transfer process before the end of 2020. This represents approximately 3% of all REACH registrations.

If you need support with your REACH registration transfers, please contact us as soon as possible.

Possible amendments to Basel Convention

The European Union and other countries have proposed amendments to the Basel Convention that could greatly increase controls and bans of international shipments of used products destined for reuse, as well as non-hazardous electronic waste.

The European Union’s proposal intends to add a new recovery operation to Annex IV of the Basel Convention – “preparing for reuse (e.g. checking, cleaning, repair, refurbishment)” – and expanding the scope of used products defined as “waste”.

Transboundary movements of hazardous waste destined for operations listed in this Annex are prohibited from OECD to non-OECD countries. It is likely that the amendment would, therefore, result in many countries throughout the world imposing import and export controls for used products destined for re-use.

In parallel, Switzerland and Ghana have proposed an amendment to add all non-hazardous electronic waste to the list of “other” waste in Annex II, which is subject to extensive prior written notification and consent, documentation, or financial requirements. Under the current framework, there are no such controls for non-hazardous electronic waste.

The proposals are now being discussed with the other Parties to the Basel Convention and a possible decision could be taken at the next meeting of the Conference of the Parties to the Basel Convention which is scheduled for July 2021.

Brexit: UK REACH and new trade regulations

Following the Brexit agreement, companies based in the United Kingdom now have a new set of rules and regulations that they must be adhere to as the UK’s own REACH system comes into effect. In addition, the new regulations will differ slightly between Great Britain and Northern Ireland.

One new obligation that will be required for all manufacturers placing electrical and electronic equipment on the market in Great Britain will be to affix a UKCA (UK Conformity Assessed) mark on these products. In Northern Ireland, these products will instead need to carry the CE mark. The CE mark will still be accepted in Great Britain up until 1 January 2022, at which point producers must switch to the new UKCA mark.

A full list of requirements, as well as guidance on how to comply, can be found on the UK government’s website.

If you have any questions on the new regulations, and how your company is affected, please contact us.

What else

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