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ECHA Discusses REACH & CLP Deadlines, Agreements with Other Countries

In a June 2010 newsletter, the European Chemicals Agency discusses, among other things, the upcoming REACH1 registration deadline for chemical substances, the related Classification, Labeling, and Packaging (CLP) Regulation deadline for chemical substances, and the signing of Memoranda of Understanding between ECHA and other countries.

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REACH Registration Deadline is Nov 30, 2010 for Certain Chemical Substances

The ECHA reminded the trade of the November 30, 2010 deadline for REACH registration of: (i) chemical substances in quantities of 1000 tons and above; (ii) carcinogens, mutagens and substances toxic to reproduction above 1 ton/year; and (iii) substances classified as very toxic to aquatic organisms (R50/53) above 100 tons.

(European manufacturers and importers must submit a registration dossier to ECHA for each chemical substance manufactured or imported in quantities of 1 ton or more per year per company. Non-EU companies who export to the EU can appoint “Only Representatives” who fulfill the obligations of the importer. Registration is required for chemical substances as such and in preparations. Failure to register means that the substance cannot be manufactured or imported in the EU. See ITT’s Online Archives or 04/09/10 news, 10040930, for most recent BP summary on REACH registration.)

Classification, Labeling, Packaging Reg has Dec 1, 2010 & Jan 3, 2011 Deadlines

ECHA also urged the trade to consider whether they have obligations under the related CLP Regulation. Under this regulation, chemical substances placed on the EU market must be classified, labeled, and packaged according to the new CLP criteria as of December 1, 2010. In addition, any such new classification, labeling, and packaging must be notified to the ECHA within one month of placing a chemical substance on the EU market, making the first deadline for notification of substances under the CLP January 3, 2011 (30 days after December 1, 2010 minus holidays).

(The CLP requires companies to classify (e.g. as carcinogenic, mutagenic, toxic for reproduction, etc.), label, and package their chemical substances according to criteria based on the United Nations’ Globally Harmonized System. For example, CLP introduces hazard pictograms that are different from the danger symbols used under the EC’s preceding Dangerous Substances Directive.For substances that are registered under REACH by November 30, 2010, notification can be done as part of the registration. Only EU-based manufacturers and importers can submit a notification to ECHA, however, non-EU companies can appoint an importer as an “Only Representative” to notify on their behalf.)

ECHA and Canada Sign MOU, Planning Similar MOUs with U.S. & Australia

ECHA also discussed the memorandum of understanding it signed in May 2010 with Canadian authorities to strengthen their scientific dialogue and increase cooperation on technical matters and other issues of common interest, including emerging risks from chemical substances or guidance development. The agency states that similar MOUs are being planned with the U.S. and Australia.

1REACH entered into force on June 1, 2007, and is intended to streamline and improve the EU’s former legislative framework on chemicals. It stands for Registration, Evaluation, Authorization and Restriction of Chemicals and places greater responsibility on industry to manage the risks that chemicals may pose to health and the environment.

ECHA information on REACH registration is available here and information on CLP is available here.