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REACHREACH
10th July 2008Kwidzyn Poland
““Business Support Programme for Bulgaria, Romania, Croatia and TurkeyBusiness Support Programme for Bulgaria, Romania, Croatia and Turkey””
BSP 2007/142-722
REACH training, 10/07/08, Kwidzyn PL 2
History background definitions ECHA Preregistration vs registration exemptions
Presentation outlinePresentation outline
REACH training, 10/07/08, Kwidzyn PL 3
backgroundbackground
2002 Johannesbourg meeting
Many regulations about chemical compounds over 40 regulations
Idea to unify the chemical market
REACH training, 10/07/08, Kwidzyn PL 4
RegistrationEvaluationAuthorisation and Restriction ofCHemicals
Regulation (EC) No 1907/2006
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This Regulation replaces: Directive 76/769/EEC, Commission Directive 91/155/EEC, Commission Directive 93/67/EEC, Commission Directive 93/105/EC, Commission Directive 2000/21/EC, Regulation (EEC) No 793/93 Commission Regulation (EC) No 1488/94
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DefinitionsDefinitions
Selected definitions: Substance: means a chemical element and its
compounds in the natural state or obtained byany manufacturing process, including any additive necessary to preserve its stability andany impurity deriving from the process used, but excluding any solvent which may beseparated without affecting the stability of the substance or changing its composition;
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Preparation: means a mixture or solution composed of two or more substances
Article: means an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition
Producer of an article: means any natural or legal person who makes or assembles an article within the Community
Registrant: means the manufacturer or the importer of a substance or the producer or importer of an article submitting a registration for a substance
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Manufacturing: means production or extraction of substances in the natural state;
Manufacturer: means any natural or legal person established within the Community who manufactures a substance within the Community;
Import: means the physical introduction into the customs territory of the Community;
Importer: means any natural or legal person established within the Community who is responsible for import;
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Placing on the market: means supplying or making available, whether in return for payment or free of charge, to a third party. Import shall be deemed to be placing on the market
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Who is concernWho is concerneded
Producers/ Manufactures
Importers
End users
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What substances are coveredWhat substances are covered
Cancerogenic Mutagenic Reproductive toxicity
PBT vPvB
…
CMR
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SDSSDS
SafetyDataSheet
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SDS SDS headingsheadings
1. identification of the substance/preparation and of the company/undertaking
2. hazards identification3. composition/information on ingredients4. first-aid measures5. fire-fighting measures6. accidental release measures7. handling and storage8. exposure controls/personal protection9. physical and chemical properties
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10.stability and reactivity11.toxicological information12.ecological information13.disposal considerations14.transport information15.regulatory information16.other information
SDS SDS headingsheadings
Example of the SDS
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ECHAECHA
EuropeanCHemicalAgency
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http://echa.europa.eu
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About ECHAAbout ECHA
Based in Helsinki, Finland Resposible for:
database Registration Examination Providing help Providing information about all ready registered/planed
compounds
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About ECHAAbout ECHA
The Agency should be financed partly by fees paid by natural or legal persons and partly by the general budget of the European Communities.
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Preregistration vs registrationPreregistration vs registration
compounds have to preregistered till 1st December 2008
Registration deadlines 30 Nov 2010 31 May 2013 31 May 2018
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Timeline for registrationTimeline for registration
Source: legislastion leaflet
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Website Website Registration through websiteREACH-IT portal
http://echa.europa.eu/reachit_en.asp
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What you need to do before submitting What you need to do before submitting your inquiry to ECHAyour inquiry to ECHA
Account creation: As a potential registrant you must sign-up in REACH-IT as explained on the account creation page of this web section. It will not be possible to send the inquiry if you do not have a REACH-IT account and a UUID for your company.
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What you need to do before submitting What you need to do before submitting your inquiry to ECHAyour inquiry to ECHA
Inquiry information requirements form: The form can be accessed via the further information heading below. You must complete the form online, download it and save it in suitable place. The completed form must then be attached to section 13 of your IUCLID 5 substance dataset during preparation of your inquiry dossier.
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What you need to do before submitting What you need to do before submitting your inquiry to ECHAyour inquiry to ECHA
Preparation of inquiry dossier: You must prepare your inquiry dossier in IUCLID 5 following the guidance in the “Manual on how to prepare an inquiry dossier in IUCLID 5 and its submission to ECHA”. Be sure to attach the “inquiry information requirements form”
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What you need to do before submitting What you need to do before submitting your inquiry to ECHAyour inquiry to ECHA
Submission form: You must download the form and complete it with the required information which must match the information you used to create your company account in REACH-IT.
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registrationregistration
First registration period till 2010
Main concern: most dangeroushigh volume
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Information for registrationInformation for registration
Substance Identity: EINECS number CAS numbers names of the substance (IUPAC, common, other)
Envisaged deadline and tonnage band for the registration 1-10 tonnes per year 10-100 100-1000 More then 1000
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Information for registrationInformation for registration
Name and contact information (of a Contact person or Third party Representative who will act as the contact point in data sharing)
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Registration abroad EURegistration abroad EU
Companies that manufacture substances, formulate preparations or produce articles outside the EU cannot (pre-)register substances. However, they can nominate an Only Representative established within the EU to carry out the required (pre-) registration of their substances that are imported into the EU.
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Third Party RepresentativeThird Party Representative
Cost sharing „Hide” some information from competitors Take care of commercial secrets
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Joint registrationJoint registration
Joint submission of data by multiple registrants
When a substance manufactured or imported by more than one company, they are required to submit certain information together
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Benefits from preregistrationBenefits from preregistration
More time!
Allow the business to run
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Pre-registration is free of charge, but…!
„producer” part of a Substance Information Exchange Forum (SIEF) until 1 June 2018 and may need to actively participate to the SIEF activities. In addition you may have financial obligations in relation to your substance.
Benefits from preregistrationBenefits from preregistration
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Did not register on time?Did not register on time?
After December 2008 will have to submit a registration dossier for that
substance before you can continue manufacturing or importing it in 1 tonne or more per year after 2008
Have to wait for registration number from ECHA
determine whether a registration or an inquiry was previously submitted for the same substance
Obtain and assess relevant physico-chemical, health and environmental data and use information in order to compile your registration dossier
Submit the dossier and pay the related fee
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Database from ECHADatabase from ECHA
After 1 Jan 2008 List of preregistered substances will be
published (website) Name Identity codes (CAS, EINECS,..) Registration deadline
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Only if you import or produce for the first time
First time counts from entering law into force 1 June 2007
Benefits from preregistrationBenefits from preregistration after 1 Dec 2008 after 1 Dec 2008
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exemptionsexemptions
medicinal products for human or veterinary use, within the scope of Regulation (EC) No 726/2004 and Directive 2001/82/EC and as defined in Directive 2001/83/EC
cosmetic products as defined in Directive 76/768/EEC
medical devices which are invasive or used in direct physical contact with the human body Directive 1999/45/EC
food or feeding in accordance with Regulation (EC) No 178/2002
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food or feeding as a food additive in foodstuffs within the scope
of Directive 89/107/EEC; as a flavouring in foodstuffs within the scope of
Directive 88/388/EEC and Decision 1999/217/EC; as an additive in feedingstuffs within the scope of
Regulation (EC) No 1831/2003; in animal nutrition within the scope of Directive
82/471/EEC
exemptionsexemptions
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exemptionsexemptions
Natural resources (minerals, ores, crude oil, gas, coke not modified)
Common elements of which hazards are well known (oxygen, hydrogen, nobel gases, nitrogen)
polymers
exemption from the obligation to register are listed in Annex IV
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exemptionsexemptions
Incidental reaction with air, moisture, mircorbiogical sunlight
Substances occuring during end use (not intented for sell)
Natural substances (occur in nature not modified)
By-products
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exemptionsexemptions
Excluded from need of registration are substances that transit through EU
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CaseCase
Import goods (eg. Paint, galvanic chemistry, fire retardant) from outside EU
-will the supplier register those goods
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Useful linksUseful links
REACH Regulation EC No 1907/2006http://eur-lex.europa.eu/JOHtml
.do?uri=OJ:L:2007:136:SOM:EN:HTML
ECHA website: http://echa.europa.eu
REACH-IT: http://echa.europa.eu/reachit
REACH Guidance Documentshttp://reach.jrc.it/guidance_en.htm