The Forum has been planning projects of harsher monitoring for REACH registration and authorisation dossiers in 2019. It has also been decided that the Forum will team up with accredited stakeholders to improve the quality of Safety Data Sheets (SDSs). In this article, EcoMundo pinpoints the changes to come.

Durcissement des contrôles des dossiers d'Enregistrement et d'Autorisation REACH prévu pour 2019

What is the Forum?

The Forum for Exchange of Information on Enforcement (or Forum) is a network of authorities responsible for the enforcement of the REACH, CLP and PIC regulations in the European Union, Norway, Iceland and Liechtenstein.

The practical work of the Forum is divided between ten working groups, which provide solutions to specific areas of enforcement. The Forum holds three plenary meetings each year.

For more information on the Forum and its tasks, visit the ECHA website .

Monitoring of REACH registration dossiers

During its 27th plenary meeting – which took place on June 2017 – the Forum decided that its seventh major enforcement project REF-7 (REACH-EN-FORCE-7) will focus on checking tasks related to registration and the registration of intermediates.

Inspectors will check whether companies that need to register substances on their own or in mixtures after the last registration deadline (in 2018) have a valid registration (Articles 6 and 7 of REACH).

Intermediates: definition

An intermediate is a substance that is manufactured or used in the chemical process in order to be transformed into another substance.

What the Forum will pay attention to in REACH registration dossiers

On top of checking already existing registration dossiers, the Forum will also make sure that the substances that are registered as intermediates are actually dealt with as such under the REACH regulation – that is to say that said substance is only to be manufactured under strictly controlled conditions, according to article 17 (3), for instance.

Katja vom Hofe, Echa's Enforcement Forum chair, said that inspectors will not limit themselves to only checking “new” registrations, submitted in 2018.

In their monitoring of registration, inspectors will also cooperate with customs authorities so as to ensure adequate control of imported substances.

The project will start at the beginning of 2019 and last a year. It will then be followed by a one-year reporting period.

Monitoring of REACH authorisation

The Forum has also decided to run a third pilot project on authorisation in 2019. The latter will deal with substances that are subject to authorisation, such as chromates and chromium VI.

chrove-vi

The recent report of the second authorisation pilot shows that about 90% of European companies are in compliance with their REACH authorisation obligations. In fact, the authorities took legal measures against the thirteen companies that failed to meet them.

Thus, inspectors will verify if companies that are using Annex XIV substances – or marketing them – have the required authorisation to do so.

This project will also start at the beginning of 2019 and is scheduled for completion in June, that same year. The report should be ready by the end of the year.

Joint action for quality SDSs

On top of all the actions previously announced, the Forum also launched its very first action in cooperation with its accredited stakeholder organisations (ASOs) – composed mostly of trade bodies and NGOs – in order to improve the quality of SDSs.

Representatives from the ASOs will join the Forum's working group (which will be set up in mid-July) to draft an action plan. The Forum will then try to identify the most common discrepancies and will develop, with the help of the ASOs, ideas to tackle these issues. Once the plan is agreed, stakeholders will be asked to communicate and implement the measures.

Want to know more about REACH registration and authorisation ?

For more information about REACH regulations, do not hesitate to contact our expert Mr Fangcun Zhou by phone : +33 1 83 64 20 54 if you are calling from Europe, or +1 (778) 234 1607 if you are calling from North America or by email at: [email protected]

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