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


Preparations for the revision of the RoHS Directive

25 February 2022


The European Commission is working on a revision of the RoHS Directive to simplify the requirements for the use of hazardous substances in electrical and electronic equipment and to strengthen their enforcement.


The Commission plans to implement the following measures:


  • revising the exemption process
  • reforming the substance restriction provisions, including timelines and procedure
  • entrusting the exemption and substance restriction assessments to the European Chemicals Agency (ECHA)
  • reforming the provisions for spare parts
  • updating and clarifying the scope of the RoHS Directive
  • introducing provisions related to recycled material and critical raw materials
  • reforming the provisions on enforcement and market surveillance, and
  • introducing provisions to ensure clear delineation between RoHS and other relevant legislation, including REACH and Eco-design Directives


Stakeholders can contribute to a public consultation which is open until 14 March. The Commission’s legislative proposal is expected to be published in the fourth quarter of this year.


Public consultation on REACH Review – moving towards European Green Deal goals


Last month’s COMPASS (see article here) introduced the topic of the revision and strengthening of the EU chemical and environmental legislation, triggered by the commitments of the EU’s Chemicals Strategy for Sustainability (CSS).


The European Commission is running a public consultation until 15 April 2022: ‘Chemicals legislation – revision of REACH Regulation to help achieve a toxic-free environment’.


They invite feedback from various stakeholders, including citizens, researchers, businesses, industry, trade associations, as well as governmental and non-governmental organisations on the proposed revision of REACH. The objective of this targeted revision is to ensure that the provisions of the REACH Regulation reflect the ambitions of the Commission regarding innovation and a high level of protection of health and the environment, as provided for in the CSS.


Comments can be submitted in any official EU language. They will be considered to further develop and fine-tune the initiative.


The proposed changes to the REACH Regulation potentially affect chemical compliance practices for many of Landbell Group’s clients. If you wish to discuss any topics as they apply to your portfolio, please contact our colleagues at H2 Compliance here.


Eight substances proposed for authorisation under EU REACH – public consultation ongoing


The European Chemicals Agency (ECHA) is considering recommending eight substances of very high concern (SVHC) from the Candidate List to be added to the Authorisation List under EU REACH. The substances are: 


  • 2-(4-tert-butylbenzyl)propionaldehyde and its individual stereoisomers
  • 2-benzyl-2-dimethylamino-4′-morpholinobutyrophenone
  • 2-methyl-1-(4-methylthiophenyl)-2-morpholinopropan-1-one
  • Diisohexyl phthalate       
  • Ethylenediamine              
  • Glutaral
  • Lead                    
  • Orthoboric acid, sodium salt


Further information on the substances, with identifiers and examples of use, can be found here.


The public consultation on ECHA’s draft recommendation to the European Commission is open until 2 May 2022. ECHA is inviting comments from industry and other stakeholders on the uses of these substances, their possible exemptions from the authorisation requirement, and on the structure and complexity of their supply chains.


After the consultation, ECHA’s Member State Committee will prepare an opinion paper, based on which ECHA will provide its final recommendation to the European Commission in spring 2023. The decision on adding substances to the Authorisation List is taken by the European Commission. It is, in parallel, inviting information on the possible socio-economic consequences of adding these substances to the Authorisation List.


For guidance on this topic, please contact our colleagues at H2 Compliance here.


Substances of Concern in Products (SCIP) database – 7 million entries over its first year


A year after the duty to notify hazardous substance in articles into the SCIP database came into force, nearly 7000 European companies have submitted seven million searchable entries, including entries from 1861 German, 1442 Italian, 499 French, 410 Dutch and 381 Swedish companies.


The duty to notify articles placed on the EU market which contain REACH Candidate List substances of very high concern (SVHCs) at a concentration above 0.1% weight by weight (w/w) is specified in Article 9(1)(i) of the Waste Framework Directive 2008/98/EC.


The SCIP database is accessible via ECHA’s website, and it is searchable by product name or category, brand or material type. This public database has significantly improved transparency on the presence of hazardous chemicals in products throughout supply chains. It is used by both consumers to inform their purchasing choices and by waste operators in their recycling and re-use operations. 


ECHA continues to provide support to submitters and users through a system-to-system automated submission service, simplified notifications and various support material, including this guidance leaflet.


If you wish to discuss this topic, please contact our colleagues at H2 Compliance here.