Chemical compliance… what’s happening?

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

Update to Candidate List

The European Chemicals Agency (ECHA) updated its Candidate List for Authorisation on 19th January to include two newly identified substances of very high concern (SVHCs). There are now 211 chemicals that may harm people or the environment included on the Candidate List.

Once listed on the Candidate List, SVHCs cannot be recommended for inclusion on the Authorisation List and future use becomes subject to Authorisation.

Under REACH Article 33, companies have legal obligations resulting from the inclusion of substances on the Candidate List.

Suppliers of articles containing SVHCs in a concentration above 0.1 % must provide the recipient of the article with sufficient information to allow safe use of the article. This obligation is effective from the date of inclusion of the substance on the Candidate List.

Under REACH Article 7 (2), importers and producers of articles containing a Candidate List substance have six months from the date of its inclusion in the list to notify ECHA.

And, as of 5th January 2021, suppliers of articles containing SVHCs must notify ECHA’s SCIP database under the Waste Framework Directive.

Please contact us for support with REACH, SCIP and SHVCs.

Amended approach for EU Safety Data Sheets

Regulation (EU) 2020/878 published by the European Commission on 25th June 2020, amending Annex II of the REACH Regulation, is applicable from 1st January 2021. This means that new Safety Data Sheets, produced after this date, will need to comply with the provisions of this Regulation.

For Safety Data Sheets compiled earlier, there is a transition period until 31st December 2022. Major amendments might be required to the existing documentation – for example, the composition information provided in Section 3.2, based on the refreshed provisions.

Please contact us for support with Safety Data Sheets.

Other key deadlines

UK – Grandfathering of existing REACH registrations must be completed by 30th April 2021. Notification of substances (already registered in the EU) and Downstream Users Notifications must be complete by 27th October 2021.

Korea – Registrations for substance >/= 1000t/a and CMRs >/= 1t/a for existing pre-notified substances must be complete by 31st December 2021. Products containing > 0.1% w/w priority control substances (list 2) with the total amount of the substance across products >1t/a must carry out a notification by 1st July 2021.

China – Since 1st January 2021, MEP Order 7 has been replaced by MEE Order 12.

India – The Draft Chemicals (Management and Safety) Rules, 20XX is expected to be finalised this year.

Belarus – Submissions to the Belarus inventory are continuing at least until the end of February 2021. This is of note to clients that may have missed the deadline for the Russian Inventory submissions. After finalisation of the inventory process, substances announced for Belarus will be added to the EAEU Register of Chemical substances. The Russian substances have already been included in the EAEU Register. This gives a second chance to clients who missed submitting to the Russian Inventory.

Taiwan – Registrations of the first batch of Priority Existing Chemicals (PECs) manufactured or imported in volumes over 100 tonnes must be complete by 31st December 2021.

Please contact us for support with any of these deadlines.

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