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Background to New Tech. Std. in EU - REACH and TSD. Shisher Kumra; Sustainability Support Service (Europe) AB Lund, Sweden . Principles within New EU Policies. No data no market Integrated Product Policy (IPP) Extended Producer’s Responsibility. Principles: IPP.
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Background to New Tech. Std. in EU - REACH and TSD Shisher Kumra; Sustainability Support Service (Europe) AB Lund, Sweden
Principles within New EU Policies • No data no market • Integrated Product Policy (IPP) • Extended Producer’s Responsibility
Principles: IPP • Env. Impacts of entire life-cycle • Manufacturing, use, disposal • Integrated Product Policy (IPP) seeks to minimize product related impacts by looking at all phases of a products' life-cycle and taking action where it is most effective.
Principles: EPR • Extended Producer’s Responsibility (ERP) is an environmental protection strategy to reach an environmental objective of a decreased total environmental impact from a product, by making the manufacturer of the product responsible for the entire lifecycle of the productand especially for the take-back, recycling and final disposal of the product”
Principles: EPR • Producer means all companies that sell in the EU: • manufacturing selling under its own brand • companies reselling under own brand other’s products • companies professionally importing or exporting into the EU • ‘first holder’ • Includes distance selling, internet sales, etc. • Producer will transfer the liability to suppliers
Amplifier Mechanism of Green Procurement Survival Competition New Global Product Policy Green Procurement Amplify Trigger - Chemical Manage. - DfE - EMS TSD RoHS REACH EuP http://www.sustainability-support.com/
No data no market REACH TSD Physical properties Chemical Properties Electrical Properties Safety and Hygiene • (SVHC) Chem. Presence in Toy (> 0.1 % wt./wt.) • Quantity of SVHC in annual exports
Integrated Product Policy REACH TSD Substitution of restricted chemicals in toys Ensure Safe design and functioning of toys With special attention to: Flammability Toxicity Hygiene Electrical Physical shape and properties • Substitution of restricted chemicals in toys • Controlled use with limited time to substitute authorised chemicals in toys • Controlled use of SVHC substances in toys
Extended Producer's Responsibility REACH TSD Exporter to appoint Authorised Representative Technical doc. to ensure that toys comply with TSD – safety assessment Declaration of conformity Followed by EC marking on toys maintain info. For 10 years • Exporter to appoint Only Representative • Notification of SVHC in Toys to ECHA • Communicate Downstream users on presence or absence of SVHC • Information on safe use of the article for downstream users
Exporter and Only / Authorised Rep. Relationship Importer, distributor, manufacturer of toys in EU Delivers toys SDS, Certificate of conformity Non EU producer of toys Notify / Tech. Doc. Appoint, and provide relevant compliance data - „Only Rep.“ / Authorised Rep. In EU ECHA / Enforcement agency Notify SVHC / Tech. Doc Enforcement