Chemical compliance… what’s happening?

What’s happening with regard to chemical regulations internationally? Here are some updates we’ve prepared for you for November 2020.

European Commission publishes Chemicals Strategy

On 14 October, the European Commission published its Chemicals Strategy for Sustainability as part of the European Union’s zero pollution ambition and the European Green Deal.

Although the strategy is non-legislative, it clearly indicates that new legislative measures will be taken including a revision of the REACH Regulation.

The document presents a set of regulatory, legislative and soft measures to be carried out in the next four years, probably resulting in a complete overhaul of the current framework for chemicals.

Among others, the Chemicals Strategy for Sustainability identifies the following priority areas:

The planned revision of the REACH Regulation is expected for 2022 and will likely aim to broaden its scope, e.g. by adding more substances of very high concern (SVHC), and to streamline processes, e.g. with regard to registration and authorisation.

The new Chemicals strategy is also going to incorporate a hazard-based approach, meaning that the most hazardous substances would be almost automatically banned from consumer products.

Another important aspect is the strategic autonomy of the European Union. The COVID-19 pandemic has emphasised the need to ensure a resilient supply of chemicals for essential applications. The Chemicals Strategy remains rather vague on how to increase resilience but refers to the Industrial Policy Strategy. However, the document indicates that the European Commission wants to create a level playing field between chemicals and products from the European Union and those from third countries.

More information on the Chemicals Strategy for Sustainability can be found here.

Brexit: Update of Guidance

Last month, Defra, the UK government department with policy responsibility for REACH, published a guidance update for the forthcoming UK REACH legislation – the first in almost 12 months. This guidance has arisen primarily as a consequence of a proposed amendment to the UK REACH statutory instrument that will extend registration deadlines.

For UK-based downstream users and distributors that will become importers from 1st January 2020

The deadline for notifications has increased from 180 days to 300 days. This means that affected UK companies will have until the 27th October 2021 to submit their notifications. These notifications will allow them to defer their new registration obligation for between two and six years after this date, depending on tonnage and hazard. Below is an excerpt from the GOV.UK website guidance detailing the deadlines:

UK government guidance

For UK-based registrants (including those who have transferred registrations to the EU)

The deadline for the first stage of grandfathering has not changed. It remains at 120 days from the 31st December 2020. Therefore, in order to benefit from an extended registration timeline, and to be able to manufacture/import into the UK temporarily without a registration, the first phase of grandfathering must be completed by 30th April 2021. After this has been completed, the same deadlines above will apply.

It is important to note that there is no general provision for extended registration deadlines, nor any expectation of “late notification” of “pre-registration” in UK REACH. Hence, to take advantage of the deferred registration timelines, either the first phase of grandfathering or a notification must be submitted. In the absence of either of these, a new full registration would be due before manufacture/import into the UK occurred at or above 1 tonne per year.

Previously, Defra have been reticent to publish guidance in the absence of any certainty – perhaps rightly so to avoid potential confusion with shifting deadlines. However, Defra having actually published an update further solidifies the idea that UK REACH will be entering into force at the end of the year. This is supported by previous statements by Defra ministers.

Hence, there should be no doubt that UK REACH is coming from 1st January 2021, and action should be taken accordingly.

For support in planning and executing your Brexit strategy, please contact us.

Turkish REACH regulation: pre-registration deadline is quickly approaching

Do you ship into Turkey? The new Turkish REACH regulation (KKDIK or Turkey REACH) is currently in the pre-registration phase which continues until 31st December 2020. Registrations for all tonnage bands must then be completed by 31st December 2023, unlike EU REACH, where different tonnages were phased in over time.

Registrants can be manufacturers, importers and only representatives. The registration requirement is for all substances manufactured or imported at or above 1 tonne per year, including substances intended to be released from articles.

The data requirements and risk assessment reports are similar to EU REACH. Reduced registration requirements apply for substances used for product and process-oriented research and to isolate intermediates. For polymers, monomers shall be registered if the volume of the monomer exceeds one tonne per year. Joint submission is mandatory.

For further information, please contact us.

What else

Huge project for huge country

Landbell Group to support reduction, reuse and recycling of plastics in India

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800 attendees, one goal: a plastic free world

Landbell Group to speak at biggest conference on reducing plastic waste

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Electrifying clothes: Mode for Recycling!

Another fantastic finale for ERP Poland’s eye-catching environmental campaign

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Helping children to unlock “The Avocado Mystery”

ERP Denmark supports children’s book on sustainable development goals

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Have you met Hermit Leer?

New campaign in Austria to raise awareness among consumers to properly dispose of waste portable batteries

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“They give us opportunity; we give them innovation.”

Interview with Anne Lamp from traceless materials, this year’s Green Alley Award winner

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Focus on… Croatia

New Waste Act makes it easier for producers to comply with EPR obligations

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A big step for Brazil

Brazil is taking its first steps in managing waste electronics and packaging - and we are proud to be accompanying them on this challenging journey 

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Study shows how producers can benefit from competition

A new study from adelphi shows that competition drives innovation, improves services and ensures cost-efficient waste management

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The Green Alley Award: jump on board

Get to know the latest circular economy business ideas… first!

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How to turn WEEE into beehives

Collecting e-waste in Lodz, Poland is now much easier and builds new homes for bees  

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Are you a parceiro sustentável?

Clients in Portugal can now find sustainability support: ERP Portugal and Novo Verde launch the “Parceiro Sustentável” programme

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Taking the pressure off online sellers in Italy

Pressure is mounting on online sellers to comply with their environmental obligations - Consorzio ERP Italia is providing a wide range of support

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Are you selling batteries into Austria?

New obligations for distance sellers of batteries are coming into force in Austria - ERP Austria is on hand to help

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Focus on… Finland

Changes for EPR – including new measures for distance sellers – as Finland begins waste management reform

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Do you like polluted beaches? We don’t either!

Landbell Group joins project to prevent marine litter in North Africa

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Why did we endorse the Ellen MacArthur Foundation statement on EPR?

Landbell Group and over 150 stakeholders commit to EPR

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You can trust us… now it’s official!

Europe's leading provider of e-commerce protection awards certificate to EASy-Shop

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Kettles reach boiling point during Irish lockdown

A kettle was the most recycled object in Ireland over the past twelve months (with 1 in 4 Irish adults claiming to have recycled one)

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Sun coming out – but be prepared for the rain

The outlook for the photovoltaic (PV) industry looks sunny again, but companies should not forget their future recycling obligations

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Focus on… Georgia

Game-changing news for companies selling electronic goods in Georgia

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Tokyo 2020: winning gold for sustainability

Olympic Games to tackle the reduction of electronic and plastic waste

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How we are responding to the global expansion of EPR

Landbell Group publishes its annual performance report for 2020

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How two men joined the fight for cleaner chemicals

Happy 15th Birthday to H2 Compliance

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