The EU REACH Regulation

Similar documents
REACH: What ITI members need to know to limit business risk

Impact of the REACH Regulation (EC) n 1907/2006

REACH and RoHS updates for EU and Asia Pacific countries Mike McNally Antea Group

REACH Compliance. (Registration, Evaluation, Restriction and Authorization of Chemicals) New EU Legislation

PLANNING FOR REACH 2018 AS A NON-EU COMPANY

REACH REGULATION: the new management of chemicals in Europe and operational tools. R egistration. E valuation. A Ch. uthorisation.

Risk Management Option Analysis Conclusion Document

Registration, Evaluation, Authorisation of CHemicals (REACH)

The European REACH Directive in a Nutshell

Micromega: REACH for Nanomaterials

Nanomaterials in REACH

10098/16 AM/mb 1 DG E 1A

Requirements for substances in articles

Strategie der EU für intelligentes, nachhaltiges und integratives Wachstum im Bereich der Chemikalienpolitik

Contents Page 1. Introduction Context of this Document How to use this Guidance Overview of REACH

Results of IPC Survey on REACH Preparedness in the North American and European Electronic Interconnect Industry

DISCUSSION PAPER ON ACCESS TO SERVICE FACILITIES AND RAIL RELATED SERVICES

AmCham EU s response to the second stakeholder consultation on RoHS II

DISCUSSION PAPER ON ACCESS TO SERVICE FACILITIES AND RAIL RELATED SERVICES. Article 1. Subject matter

REACh How does it affect the pharmaceutical industry? Consideration of the issue for a medium-sized enterprise.

Collection of chemical substance content information

Chinese Chemicals Regulation and the influence from EU REACH

16361/14 AM/am 1 DG E 1A

Interface between REACH and CAD:

REGULATIONS. L 44/2 Official Journal of the European Union

QUESTIONS AND ANSWERS ON MRP & DCP AND EU ENLARGEMENT

FEASIBILITY OF A MATERIALS INFORMATION PLATFORM AND THE WAY FORWARD

This document is meant purely as a documentation tool and the institutions do not assume any liability for its contents

Exploring Communication in the Supply Chain under REACH Authorisation process

Import tolerances in the European Union Can Import Tolerances be set for active substances impacted by the EU hazard-based criteria?

PAN Europe s briefing on:

Product Stewardship Due Diligence

Review of the List of restricted substances under RoHS II

REGULATORY ACTIONS UNDER REACH & CLP FEEDBACK FROM ECHA S RAC

Restricted Substance List (RSL) Medical Devices

3: REACH Case Story Summaries

Brexit Guidance for Stakeholders Human and veterinary medicines

Justification Document for the Selection of a CoRAP Substance

Justification Document for the Selection of a CoRAP Substance - Update -

European Parliament resolution of 8 March 2011 on the revision of the General Product Safety Directive and market surveillance (2010/2085(INI))

Science Forum Biofach, 11 th February 2016, 16:00-17:30

TUR Options Identification and Evaluation

Risk management get ready

REACH REGISTRATION 2018 WHAT TO KNOW ABOUT THE COMPLIANCE DEADLINE International Aerospace Environmental Group. All rights reserved.

The Interface between REACH and CAD/CMD

Approved Employer (AE) Programme Handbook

SWISS ORDINANCE ON MATERIALS AND ARTICLES IN CONTACT WITH FOOD (SR ) Permitted Substances for Packaging Inks. Questions & Answers

An introduction to socioeconomic analysis in the REACH authorisation process

Advancing the Environmental Agenda

Analysis of Alternatives and Socio-Economic Analysis

REACH and You. Con Expo / Con Agg 2014 March 5,

Closing remarks. Seminar on applications for authorisation 17 June Tomas Öberg Chair of Socio-economic Analysis Committee ECHA

Petroleum Products in the REACH Regulation Klaas den Haan, Stewardship Conference, SCL 1 June 2015

Implementation of toxicological data from other legal provisions (e.g. REACH) An industry perspective

BOM Intelligence: solving the challenges of the electronic component supply chain

REACH 2018 Registration Deadline

CHEMICAL COMPLIANCE THEWERCS.COM 1

Global Developments in Regulation of Chemicals. Implications of New EU Regulation of Biocides

This guide is designed to simplify packaging compliance and help demystify the process to becoming compliant.

Delegations will find enclosed the draft text of the REACH Regulation as agreed by the Competitiveness Council at its meeting on 13 December 2005.

EU Environmental Compliance:

Information Services & New Jersey Sales Tax

Organisational Change Policy and Procedure

Transparency and sustainability of the EU risk assessment process

Audit report VET Quality Framework

Feedback from ECHA on dossier and substance evaluation

By: Paul Beatley 16 April 2015

In line with ONGETTA SRL s long term sustainability program ONGETTA SRL recognizes the urgent need for

Diversity Policy. Shine Corporate Ltd (the Company ) Contact. ACN Level 13, 160 Ann Street Brisbane QLD 4000 Australia

Guideline on the implementation of. European Regulation (EC) 1272/2008

This document is meant purely as a documentation tool and the institutions do not assume any liability for its contents

Chemical Substance Control Law; CSCL Japan

PROBUILD GUIDE SUBCONTRACTOR QUALITY MANAGEMENT. Section Two Project Specific Quality Management Plans. Version No 1.

Webinar - REACH Registration 2018

COCIR SUSTAINABLE COMPETENCE IN ADVANCING HEALTHCARE

Tesco Greenpeace Detox Commitment

ORGANIC CERTIFICATION PROCESS IN NON-EU COUNTRIES

OPAC EN Operating Procedure for the Attestation of Conformity of Structural Bearings in compliance with Annex ZA of EN 1337/3/4/5/6/7

Proposal for the implementation of the authorised representative under Directive 2012/19/EU ( WEEE2 ) July 2013

Global Regulatory Service Hand in hand with our customers. English B-13

Application for Pro Bono Legal Assistance (Updated 5/4/2016) Part 1: Prospective Client Contact Information. 1. Organization: TODAY S DATE:

REQUEST FOR PROPOSALS EXECUTIVE SEARCH SERVICES. Issuance Date November 27, 2017

COUNCIL OF THE EUROPEAN UNION. Brussels, 30 November /05. Interinstitutional Files: 2003/0256 (COD) 2003/0257 (COD) LIMITE

ISCC 204 AUDIT REQUIREMENTS AND RISK MANAGEMENT. Version 3.0

Implementing EC Regulation 1071/2009 Rules Concerning the Occupation of Road Transport Operator

How employers should comply with GDPR

Prepared in the framework of the Study for the Review of the List of Restricted Substances under RoHS2 Reference: ENV.C.

Update from ECHA. REACH Information and Experience Exchange Forum (RIEF IV) CEFIC 19 June 2015 Sheraton Brussels Airport Hotel

FMCG Business Confidence Report H Reference code: CS4625PR Published: July 2015 Single user price: US$1950

In the huge expanse of Asia, Singapore and

Adriana Jalba Ph.D. Manager ICM, Cefic

Guideline on good pharmacovigilance practices (GVP)

Am I in? A guide to qualification and organisational structure

Aluminum Electrolytic Capacitors


EUROPEAN TYRE & RUBBER manufacturers association

Review of the scope of REACH and other relevant EU legislation according to Article 138(6) REACH: description of gaps and overlaps

Recent U.S. EPA Initiatives on Chemical Testing and Assessment: Where's the Beef?

1. Council conclusions on strengthening the balance in the pharmaceutical systems in the EU and its Member States

Transcription:

The EU REACH Regulation CMS Supply Chain Innovation Workshop WSP Environmental Strategies October 25, 2007

Agenda Introduction How Will REACH Impact Industry? Key Elements and Timetable Potential Consequences of Inaction What Should Companies be Doing? REACH and CMS Providers Data Needed for REACH Getting Started What are the Opportunities for CMS Providers? Resources

WSP Environmental WSP is a global supplier of environmental, health & safety, energy, and social responsibility consultancy services 12 years of consistent growth in staff and revenue 1000 staff employed in 60 offices across Europe, North America, Africa, Middle East, Australia and Asia Pacific, with headquarters in London

Introduction One of the most complex pieces of legislation to ever come out of Europe REACH Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation Implements the new EU Chemicals Policy Represents a radical overhaul of existing chemicals legislation replaces 40 existing laws controlling chemicals Entered into force on June 1 st 2007 Presents ambitious challenges for industry and CMS providers Will likely result in chemicals disappearing from the supply chain and the need to revise manufacturing processes/reformulate process chemicals.

How Will REACH Impact Industry? REACH covers: Chemical substances and preparations manufactured in the European Union Substances and preparations imported into the European Union Articles (products) manufactured and imported into the EU And potentially impacts: Companies with EU operations that consume chemicals Companies elsewhere that utilize chemicals from the EU Manufacturers of articles to be sold in the EU, regardless of where the articles were manufactured Manufacturers of chemicals or preparations sold in the EU Chemical companies Manufacturers who sell reagents used in their products The chemical supply chain, including CMS providers REACH presents both burdens and opportunities for industry

Key Elements and Timetable Pre-registration Straightforward procedure To establish database and aid working together in groups Registration By manufacturers and importers Submission of data & safety assessments Eventually all chemicals > 1tonne/annum Initially addresses high tonnage and chemicals of high concern Evaluation Of the submitted data by the authorities Call for missing / extra data

Key Elements and Timetable Authorisation Only for substances of very high concern Mandatory substitution if safer alternatives exist Continued use on socio-economic or adequately-controlled grounds Time limited Exemptions from scope: Substances in regulated products (i.e. medicines, cosmetics) Annex IV substances (i.e. C0 2, glucose, water) Annex V substances (i.e. manufacturing by-products, certain substances occurring in nature, elemental substances) Polymers (although monomers in polymers in scope if sold separately) Others

Key Elements and Timetable Articles Objects that have been given a special shape, surface or design which determines its function to a greater degree than its chemical composition Examples: computers, printers, circuit boards, cars, pens, etc. As opposed to substances (individual chemicals) and preparations (mixtures of one or more substances) Notification and registration potentially required if: SVHCs (Substances of Very High Concern) are present >.1% by weight and in amounts over 1

Key Elements and Timetable Substances of very high concern (SVHCs) Defined in Annex XIV of REACH. Examples include carcinogens, mutagens, persistent and accumulative substances, endocrine disrupters REACH designed to induce manufacturers of SVHCs to voluntarily withdraw these substances from the marketplace, potentially disrupting supply of raw chemicals to industry Candidate list of SVHCs to be made available by EU by June 2009 Reasonable level of confidence regarding which substances will be listed as SVHCs. Some industry lists are being developed.

Key Elements and Timetable June 1 st 2007 REACH Enters into force June 1 st 2008 Pre-registration begins Nov 30 th 2008 Pre-registration finishes December 2008 List of Pre-registered substances published Nov 30 th 2010 Registration deadline for >1000t/annum substances Substances of Very High Concern May 31 st 2013 Registration deadline for >100t/annum substances May 31 st 2018 Registration deadline for >1t/annum substances

Potential Consequences of Inaction If substance is unregistered, it will be illegal to put it on the market in the EU Risk of disruption to raw material supply chain and manufacturing operations May come under increasing scrutiny by customers and nongovernmental organizations Chemical risks and impact to company liability may not be addressed Companies may absorb costs they shouldn t have to bear Potential for fines and penalties Potential for product liability claims

What Should Companies be Doing? Understand how REACH applies to the company and business partners Determine registration obligations and pre-register if applicable Determine compliance dates that will drive compliance and implementation Identify business risks including vulnerability of supply chain to disruption Identify gaps in data and processes that will be needed to support REACH compliance Begin communicating up and down the supply chain

REACH and CMS Providers First, the bad news: CMS providers may have direct REACH registration obligations if they import chemicals into the EU Exception: where the non-eu chemical manufacturer has contracted with an only representative and relieved the CMS provider of registration responsibility Customers likely to look at REACH as an issue that the CMS provider is being paid to manage Costs of REACH will increase costs of chemicals The good news: CMS providers are positioned to assist their customers with REACH and create value, for example : REACH awareness and training for customers Providing data needed by customers to comply with REACH Facilitating communication up and down the supply chain Anticipating supply chain disruptions and providing alternatives Collaborating with customers on chemical substitution needs Supporting customer efforts toward eliminating the most toxic and dangerous chemicals from the supply chain

Data Needed for REACH Gathering data needed to support REACH compliance may require cross-functional support within a business: Categories of Data Chemical substance data Material composition data Sales channel data Supply chain data Product volumes sold Business process data Potential Data Sources Procurement personnel EHS personnel Supply chain managers Sales personnel R&D laboratory managers Manufacturing Operations Legal and contracts

Getting Started Applicability assessment: High level determination of how REACH affects your business and your partners (chemical suppliers, importers, downstream users, components suppliers) Identify key criteria that will determine specific responsibilities for your company Define timeframes for compliance Determine high-level estimate of potential costs Define the business case for REACH and being proactive REACH may result in disruptions of availability of chemicals Could result in need to find and qualify substitute chemicals, which could take 1-2 years Proactivity should contain costs and minimize disruptions Communicate results within your organization and build support

Getting Started Assessing vulnerability of supply chain List your inventory of chemicals utilized in manufacturing Determine supply chain partners and ultimate source of chemicals Review for presence of SVHCs Identify substances that are likely to be withdrawn due to REACH Communicate with suppliers on their plans for supporting your chemicals through REACH Initiate chemical substitution and qualification where risk of disruption is significant Develop a REACH strategy Proportionate to applicability and potential business risk Detailed action plan based on applicability assessment and supply chain vulnerability Internal, external resources and expertise

REACH Resources European Commission REACH website: http://ec.europa.eu/environment/chemicals/reach/reach_intro.htm European Chemical Agency (ECHA) website: http://ec.europa.eu/echa/home_en.html WSP: In the US: Doug Lockwood, Senior Consultant Phone. (831) 915 9563 Email: doug.lockwood@wspgroup.com In the EU: Kate Geraghty, Principal Consultant Phone: +44 (0)121 352 4897 Email: kate.geraghty@wspgroup.com WSP Environmental REACH website: www.reach-answers.com

Questions?