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REACh, tanners and the role of Research Centers The example of CTC

REACh: Regulation, Evaluation, Autorisation and Restriction of Substances. REACh, tanners and the role of Research Centers The example of CTC. Thierry PONCET Régis LETY tponcet@ctcgroupe.com Tel : 33.472 76 10 05. Should European tanners read the 840 pages of REACh?. Pre-Registration.

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REACh, tanners and the role of Research Centers The example of CTC

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  1. REACh: Regulation, Evaluation, Autorisation and Restriction of Substances REACh, tanners and the role of Research CentersThe example of CTC Thierry PONCET Régis LETY tponcet@ctcgroupe.com Tel : 33.472 76 10 05

  2. Should European tanners read the 840 pages of REACh? Pre-Registration information on 40 000 substances > 1t/year/manufacturer All substances (Pure/preparation/in products) Registration manufacturer/importer Analysis of 1st level Echa Evaluation of 2nd level Evaluation member states Very high concern substances (CMR, PBT, vPvB)* Temporary authorisation with obligation of substitution asap Authorisation CMR : Carcinogenic, Mutagenic Reprotoxic I et II PBT : Persistent, Bioaccumulable and toxic vPvB : very Persistent, very Bioaccumulable Restrictions

  3. Chemical importer Pre-registration Downstream user Inform chemical suppliers that the chemical is used in the tanning industry. Exposer scenario Article manufacturer: Does the leather sold complies with REACh? Each supplier shall give to the products user at least, the name of the very high concern substances present in the products, if : - CMR 1/2, PBT, vPvB - C > 0.1 % (1 g/kg) STEP 1- What is a tanner and what to do ?

  4. Chemical importer Pre-registration Downstream user Inform chemical suppliers that the chemical is used in the tanning industry. Exposer scenario for the Chemical Report Article manufacturer: Does the leather sold complies with REACh? Each supplier shall give to the products user at least, the name of the very high concern substances present in the products, if : - CMR 1/2, PBT, vPvB - C > 0.1 % (1 g/kg) STEP 1- The answer of Research Centers • The answers of the Research Center • Knowledge Management / Information • Determin what are the substances of Very High Concern in Leather? • Benchmarking on Chemical Testing • Tool and methodologies • How to determin what are the Substances of Very High Concern? • Data Base on Chemical Safety Data based • Data Base on Restricted Substances • Propose Model Letters.

  5. > What is the candidate list to annexe XIV? Annex XIV will be published on June 1, 2009

  6. > What are the candidate Substances to annexe XIV? Phtalates (DEHP, DBP, BBP) Chromium VI Chloroalkanes C10-13 Lead Annex XIV will be published on June 1, 2009

  7. STEP 2 - REACh consequences • Beginning of October: 38 000 Commercial References pre-registrered • CTC’s Chemical Data Base: > 2.400 Commercial References • 450 substances used in the Tanning Industry (not exhaustive) • Pre-registration up to November 30th.

  8. Step 2 – The Answer of Research Centers • Before 30 November 2008 • Identify what chemical haven’t been pre-registered • Identify what are the corresponding Commercial References • Alert the Chemical Suppliers • After 30 November 2008 • Search for alternative chemicals

  9. Conclusion • REACh, as most regulations is a constraint for the European Tanners. • Instead of having each tanner doing the job by itself, Research Centrers have to prepare collectivelly their single work by providing • Information • Tools and methodology • Communications, model letters • Research programs

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