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REACH

TAIEX Workshop on the REACH Regulation and Its Application in Textiles, Leather and Shoes Production “REACH & Its Practical Application on Textiles ” November 12, 2009. REACH. By Adil ELMASSI Head of Environmental Affairs.  Do I need to pre-register and register substances in articles?

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REACH

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  1. TAIEX Workshop on the REACH Regulation and Its Application in Textiles, Leather and Shoes Production “REACH & Its Practical Application on Textiles ” November 12, 2009 REACH By Adil ELMASSI Head of Environmental Affairs

  2.  Do I need to pre-register and register substances in articles? •  Do I need to notify substances in articles? • Do I need to forward information on substances in articles to my customers or to the consumers? • The application of substances in articles provisions is a serious challenge for EU importers of yarns, fibres and grey fabrics as well as finished articles • WHY? • Lack of information on the production process and the corresponding chemicals input

  3. Substances in Articles • Obligations–EU Importers • Registration according to article 7(1) •  Intended release • Total amount exceeds 1 t/a •  The total amount of the substances in all articles is taken into account •  If more than one type of articles with intended release of that substance, the quantities in all articles have to be summed up •  The substance does not have to be registered if already registered by an actor in the supply chain

  4. Notification according to article 7(2) • Only when all conditions are met: •  The substances is included in the candidate list for authorisation (article 59(1)) •  Is present in all articles in amount totalling over 1t/a • Is present in the articles above 0.1% (w/w) • Notification is not requested if one of the following conditions is met: •  Exposure is excluded •  The substances has already been registered for the use in the article

  5. Notification according to article 7(2) • IMPORTANT to note • 0.1%(w/w) threshold is applied to an article as imported and not to the homogeneous parts of an article • Substances being part of imported articles cannot be subject to authorisation

  6. Duty to Communicate Information on Substances in Articles - Obligation according to Article 33 • Articles 33 ensures that sufficient information is communicated with articles to allow safe use •  Information has to be also provided to consumers upon request within 45 days • It concerns SVHC present in the article in concentration above 0.1% •  The obligation cannot be exempted via article 7(3) (exclusion of exposure) • The obligation cannot be exempted via article 7(6) ( already registered for that use)

  7. Obligations according to Article 33 • IMPORTANT to note • There is no tonnage trigger for this obligation • The obligation applies once SVHC has been included on the candidate list for authorisation • The date of supply of articles is relevant • The obligation apply also to articles which were imported before the substance was included in the candidate list and are supplied after the inclusion in the that list

  8. RESTRICTIONS • The content of substances in imported articles can be restricted or banned •  Importers of articles has to follow the conditions outlined in annex XVII of REACH from the 1 June 2009

  9. Table 1 : Timelines for Article Importers

  10. Packaging and containers • Importers of packaged articles have to fulfil the same requirements for that packaging as for any other article, be it a carton or a plastic wrapping • In general no intended release from packaging materials is foreseen but they may be unintended release.

  11. Be Prepared to communicate Information to your EU Customers • Article Suppliers to the EU: • Should document the results of their compliance checking with the requirements of substances in articles and information to consumers • With implemented Environmental management systems could incorporateREACH conformity as a criterion with a clear indication of how conformity will be secured and documented •  May establish “good practice code” with supporting documents including letters to importers, certificates, results of analysis etc.

  12. Standardised information from non-EU suppliers • Part of the information needed to comply with Art 7 & 33 can be derived from the SDS (art 31) or information required for substances subject to authorisation /restriction for which no SDS is required ( Art.32) • Article importers will not receive any comparable standardised information ( supply chain outside the EU)

  13. Requesting non-standardised information • In this case you will face an active request for information on the identity of the SVHC and on the concentration/amount contained in the articles I M P O R T A N T to note  The textile supply chain is complex, confidentiality and contractual obligations may hinder communication and information flow.  This type of enquiries will need time and resources and concertation between the actors

  14. NON-EU Exporters can play a role in facilitating the process and reducing the work load • Excluding the use of SVHC: • This could be done “top down”: • by certifying that SVHC are not used • or remain under certain concentration range in articles. • The “bottom up” approach consist of EU importer including criteria in supply contracts

  15. Recommendation for a strategy to consider • Narrow down the range of SVHC in the candidate list by using the “ exclusion” approach • Consider 0.1% (trace amounts would normally not exceed the threshold) • Consider when relevant the 1t/a threshold (substances in articles requirement) • Exhaust options for obtaining information via your supply chain • Only as last resort conduct targeted analysis

  16. Determining whether the article contain SVHC  Be aware of the possibility to accumulate SVHC through the production process  If the exact concentration in the article is not known , a first screen may be performed on the basis of the maximum amount or concentration in the article. If it shows a concentration > 0.1% a more precise determination of the SVHC amount or concentration should be made

  17. Excluding exposure for substances in • articles • Exposure can be excluded in the following situations: •  No release occur •  There is a release but the article is embedded during use and the substance will not escape to the environment or get into contact with humans during use and disposal

  18. Excluding exposure • include arguments based on: •  Knowledge of the article and its service life •  Knowledge on the substance properties •  Quantification based on exposure models demonstrating no exposure during the life cycle and disposal • Measurements proving that no emission from the article take place including during its disposal It maybe more difficult and more expansive to “exclude exposure” than making a notification to the Agency

  19. Thank you for your attention Adil ELMASSI HEAD OF ENVIRONMENTAL AFFAIRS EURATEX

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