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The eu REACH regulation 10 common problems

Article keywords:2018-09-12 14:30:01

Q1: what is the REACH regulation?

A1: REACH is the eu regulation (EC) No. 1907/2006 "registration, evaluation, authorization and restriction of chemicals. The legislation was released on December 31, 2006, formally went into effect on June 1, 2007. In order to guarantee the smooth implementation of the regulations, the eu set up the authority the European chemicals agency (ECHA), formally on June 1, 2008.

Q2: control of the REACH regulation which products?

A2: the eu market products as long as the obligations relating to the rules and regulations related to chemicals, you need to comply with the REACH regulation. So the control of the REACH regulation range is very wide, contains the electrical products, chemical products, such as automobiles, toys, furniture, textiles and other products.

Q3: REACH the product is divided into material, mixture and three types of products of different types have different requirements. This classification is how to define?

A3: three types of products are defined as follows:

"Matter" refers to the state of nature or by the manufacturing process of chemical elements or compounds, such as cadmium, copper sulfate, etc. Include any need to keep the stability of the additive and the introduction of impurities in the course of production, but does not include anything that is separation does not affect the physical stability or composition of the solvent.

"Mixture" is to point to by two or more substances consisting of a mixture or solution, such as paint, alloy, cleaning agents, etc.

"Goods" means a product in the process of production is endowed with specific shape, surface or design, the shape, surface or design is bigger than its chemical composition extent determines its function. For example: computer, mobile phone, motor, gear, the power cord plugs, packaging materials, etc.

Q4: REACH to the requirement of hazardous substances including what? The concentration of SVHC candidate material in the product is not more than 0.1% can think meet the requirements of the REACH regulation?

A4: REACH the requirement of laws and regulations about hazardous substances mainly involve SVHC candidate material and annex XVII restricted substance two group, products exported to the eu must consider these two requirements at the same time.

If the product belong to the category of "items", a SVHC candidate material > 0.1%, the product can be sold in the eu, but need to inform the duty. When the SVHC candidate material > 0.1% > 1 ton/year, and exports to the European chemicals agency after reporting to sales. Restricted substances listed in annex XVII of the REACH regulation. Substances, mixture or articles contained in the restricted substances in annex XVII, if he doesn't conform to the requirements of the threshold, will not be able to put on the market.

Products, therefore, the concentration of SVHC candidate material in not more than 0.1% is not the same as meet the requirements of the REACH regulation, also need to assess whether products may be in violation of the terms of the restricted substances in annex XVII, if necessary by test determine whether meet the requirements of annex XVII.

Q5: REACH the limit value in annex XVII is aimed at a finished product or homogenous material?

A5: from the point of the REACH provisions in annex XVII, most of the substances in annex XVII limit needs to be homogenous materials for judgment, rather than the finished product, to this point and SVHC candidate material requirements.

Q6: how do enterprises deal with the REACH annex XVII requirements?

A6: there are 64 entries in annex XVII, every item on the product category, control material are different. Article 5 for the benzene limit requirements, for example, its for object for material, mixture and children's products; Again such as article 64 to 1, 4 - dichlorobenzene limit requirements, its for object for air freshener/deodorant. As a result, is the most important thing to annex XVII of the REACH regulation in combination with the actual situation of its own products to identify needs to focus on the material in the annex XVII, consider to take corresponding control measures to ensure that meet the requirements of laws and regulations.

Q7: the situation of REACH regulation in Europe?

A7: due to the requirements of the REACH regulation is very diverse, and its implementation methods are different according to the different requirements, and the entire level have a coordinated European chemicals agency, all kinds of environmental protection organizations, as well as consumers to REACH implementation will also actively promote. Non-food consumer goods now in the European union rapid alert system (RAPEX) more than 50% of cases are due to violation of the appendix of the REACH regulation XVII excess levels (such as nickel release a quantity to exceed bid, plasticizer, containing asbestos, etc.) and be notified, and fully embodies the eu attaches great importance to REACH regulation.

Q8: where can I learn about the official information of the REACH regulation?

A8: by the competent authority of the REACH regulation the European chemicals agency official website to understand. The website the latest dynamic information, in addition to providing regulations also provide a variety of tools to assist enterprises to more easily identify and fulfill the obligations of the REACH regulation.

The European chemicals agency website: http://echa.europa.eu/

Q9: SVHC candidate substance frequently updated, phyletic and various, enterprises need to spend a lot of testing costs to cope with, HUT if you can provide some advice?

A9: to explore the management of the SVHC requirements of the REACH regulation, its core lies in the supply chain in effective control of SVHC information and transfer, in order to realize effective regulation of chemical safety in the supply chain. In general, SVHC survey of mastery and information transfer can be material risk analysis, testing, raw material composition table, MSDS, application of supply chain materials combine a variety of ways, such as, according to the different material characteristics of risk and choose the right way, to reduce the cost of implement effective grasp of SVHC information and transmit at the same time. According to the different ways, leading domestic third-party testing certification bodies TCT can provide corresponding Suggestions and solutions, and can according to the enterprise actual situation tailored solutions for the enterprise.

Q10: according to REACH regulation, HUT can provide enterprises with which solution?

A10: currently, HUT can provide customers with comprehensive one-stop solution of the REACH regulation, including:

1) training and consulting: HUT can provide enterprises with all-round training, provide technical support for REACH compliance strategies;

2) the SVHC candidate list and annex XVII material testing services: HUT the testing service to determine the products of these chemicals to provide reliable evidence of its existence, conform to the requirements of the REACH to lay the foundation for the enterprise;

3) SDS/MSDS service: HUT can make for the enterprise to meet the requirements of eu REACH SDS, assist enterprises in the supply chain transfer effective chemical toxicology characteristics, ensure the security of the chemicals used;

4) REACH conformity declaration services: the analysis of enterprise products REACH obligations, and the enterprise has the control of work, on the basis of a series of assessment, HUT to conform to the requirements of the REACH of product REACH compliance certificate, help enterprise one pace reachs the designated position to prove the REACH conformity of the product.

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