| Chemicals agency
sheds light on substances in articles with new published guidance under
REACH
dated June 2008
On 1 June 2008, the European Chemicals Agency (ECHA) opened up
to pre-registrants of chemical substances that are placed on the EU
market, either on their own or in preparations, or else in articles
where their release is intended. ECHA has warned that due to current
instabilities in the REACH-IT portal, the latter is at this stage only
available for company sign-up and online pre-registration. Data for
pre-registration of a single substance can be entered and submitted
online via the REACH-IT portal. A pre-registration of several substances
in one file (bulk registration) will be available at a later stage.
On 3 June, EU Commission president Manuel Barroso, presiding at an
inaugural ceremony at the ECHA in Helsinki, proclaimed the establishment
to "be a key milestone". Since opening on 1 June, ECHA has received
details of some 2,000 pre-registration requests. Officials estimate that
by 1 December 2008 (the closing date for pre-registrations), this number
could have risen to as many as 200,000.
|
On 26 May 2008, the ECHA
published its Guidance on requirements for substances in articles (the
Guidance). The Guidance provides valuable information on, among other
things, registration of substances in articles (including on deciding
what is an article rather than a preparation); the notification process
applicable to substances in articles even where no registration is
required; and the requirement for articles suppliers to communicate to
recipients in the supply chain.
Hong Kong's manufacturers of articles exported to the EU should already
be familiar with the REACH definition of articles: "an object which
during production is given a special shape, surface or design which
determines its function to a greater degree than its chemical
composition." While in principle all substances -- on their own or in
preparations -- of one tonne or more per year will need to be registered
(and, if phase-in substances, pre-registered), substances in articles
only need to be registered where:
• the substance is intended to be released from the articles
during normal and reasonable foreseeable conditions of use;
• and the total amount of the substance present in the
articles exceeds one tonne per year per registrant.
Even then, registration is not required where the substance has already
been registered, by any other person, for that use. |
