Life Cycle Thinking Blog

ECHA reminds submitters to get in early for the second round of REACH applicable to manufacture or import between 100 – 1,000 metric tonnes/yr of a chemical substance not previously registered. The official deadline is May 31, but since many dossiers have been incomplete in the past, lead registrants are strongly advised to get their dossier in by March 31.

ECHA has recommended 10 Substances of Very High Concern to go onto the Authorization list.  Once finalized by the European Commission, Member States and EU Parliament, sunset (ban) dates will be set and companies will need to file and get authorization for use approved to continue marketing past those dates.

There are now 138 Substances of Very High Concern under REACH with the addition of another set of 54 chemicals December 19, 2012. Producers and importers of articles have 6 months to notify ECHA if articles contain more than 0..1% by weight and the use hasn’t already been registered.

Companies need to keep on top of new listings (about every 6 months) and be prepared to find out whether articles you make, sell or buy contain >0.1% adding to more than 1 metric tonne/yr.

Pointed comments by outgoing CEFIC (European Chemical Industry Council) president Squinzi on REACH here. One highlight on the 2 billion euro cost since 2007…

Helpful webinar slides and audio have been posted on ECHA’s site regarding the CoRAP evaluation process on chemicals registered under REACH.

Presentations emphasize the tight time frame for the evaluations and the need to coordinate with fellow registrants so you have a central contact point (likely the lead registrant) to deal with issues around new testing and data submissions that may be raised by the evaluating member state. ECHA speakers reminded people that the listing on CoRAP does not mean there will be any change in current regulation of the chemical. Of course, time will tell.

Whew! Make that 54 more chemicals ECHA is looking to add to the Substances of Very High Concern (SVHC) here. See if your favorite is on the list and comment if you want by October 18.

Phthalates, nonylphenols, a bunch of lead compounds, propylene oxide, TDA and more….

For those of you who like to get ahead of official listings under REACH, ECHA has a posting of “intentions” to list new SVHC Candidates, proposed restrictions and classification and labeling harmonization proposals: http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/registry-of-intentions

Also be aware that there’s also a push to really up the number of SVHC by the end of the year (to 136 from the current 84).

ECHA’s Registered Substances Database contains 7,530 unique substances with information from over 30,000 dossiers.
A little under 3,000 chemicals have been identified as “intended” to be registered with the next deadline of May 31, 2013, for chemicals in the 100 – 1000 metric tonnes range.

ECHA is taking comments on the next batch of chemicals likely to be subject to authorization:
1. formaldehyde, oligomeric reaction products with aniline (technical MDA)
2. arsenic acid
3. dichromium tris(chromate)
4. strontium chromate
5. potassium hydroxyoctaoxodizincatedichromate
6. pentazinc chromate octahydroxide
7. bis(2-methoxyethyl) ether (diglyme)
8. N,N-dimethylacetamide (DMAC)
9. 1,2-dichloroethane (EDC)
10. 2,2′-dichloro-4,4′-methylenedianiline (MOCA)

The REACH Substances of Very High Concern (SVHC) Candidate List just keeps getting longer: 13 more added from the CMR (carcinogen, mutagen, reproductive toxin) category: check the top of the current SVHC Candidate List
Remember: listing triggers notice to ECHA for articles within 6 months (unless use already registered) and informing customers if >0.1%. obligations