Chemical compliance… what’s happening?

What’s happening with regard to chemical regulations internationally? Here are some updates we’ve prepared for you for June 2022.

A roadmap towards restricting the most harmful chemicals

On 25 April 2022, the European Commission published a Restrictions Roadmap – an important step towards phasing out the most harmful chemicals unless their use is proven essential.

The roadmap prioritises restricting groups of chemicals and details all ongoing and future restriction work under EU chemical legislation. It presents a rolling list of substances that will serve as the basis for planning restrictions under the REACH Regulation. The list will be regularly reviewed and updated.

The Restrictions Roadmap is a deliverable under the Chemicals Strategy for Sustainability which calls for action towards a toxic-free environment. For industry, this adds one more factor to the complexity of managing product stewardship programmes and goals. In addition to regulatory compliance, companies are also faced with customer and supply chain pressures for transparency and safer products.

Landbell Group’s chemical and environmental consultancy, H2 Compliance can assist in identifying and implementing strategic and tactical product stewardship solutions for global supply chains. These solutions span the product’s entire lifecycle, from raw material sourcing and supply chain data management, through to product manufacture, distribution, use, and end-of-life.

Please get in touch to learn how H2 Compliance can help organizations to not only comply with regulations, but become an industry leader in product stewardship – to promote a safer, greener future.

EU REACH only representatives need to declare their non-EU manufacturers by 14 October

The European Commission has revised certain information requirements for registering chemicals under REACH. This includes the obligation to identify non-EU manufacturers and provide their contact details in the registrations submitted by their only representatives (ORs).

The following information needs to be provided in the European Chemical Agency’s submission tool REACH-IT by 14 October 2022:

• non-EU manufacturer’s full contact details and contact person
• location of any production or formulation sites
• respective national company identification numbers

As a reminder, non-EU producers can appoint ORs to take care of REACH registrations and other compliance needs for their chemicals. This is commonly done to provide registration coverage for their European importers.

If you are supplying chemical products to European customers or have registered as an OR, you may need to update or reorganise the REACH-IT accounts.

ECHA has published a manual to help companies with the task.

Landbell Group’s consultancy, H2 Compliance acts as OR for over 100 companies globally and is very well placed to help you understand the requirements, implement the changes, or act as your representative under REACH. 

Consultations and legislative initiatives

REACH

Restriction proposals

• Per- and polyfluoroalkyl substances (PFASs). Deadline: 23/09/2022           
• Polycyclic aromatic hydrocarbons (PAH). Deadline: 22/06/2022

Harmonised classification and labelling (CLH)

12 CLH consultations ongoing on various substances

Restriction of the use of hazardous substances in electronics (RoHS) Directive

The public consultation of the review of the RoHS Directive closed on 2 June 2022. Commission adoption is planned for Q4 2022.

Sustainable Products Initiative

This initiative revises the Ecodesign Directive and proposes additional measures to improve the sustainability of products placed on the EU market. It also addresses the presence of harmful chemicals in products such as electronics and ICT equipment, textiles, and furniture.

As part of the European Commission adoption process, the adopted act is open for public feedback from 03 April 2022 to 22 June 2022. All feedback received will be summarised by the European Commission and presented to the European Parliament and Council with the aim of feeding into the legislative debate.

Revision of EU rules on food contact materials

This initiative concerns food packaging and aims, among other things, to reduce the presence and use of hazardous chemicals, as well as the sector’s environmental impact: a public consultation is planned to take place later in 2022, before adoption by the European Commission in Q2 2023.