The registration process for EU REACH

There is no such thing as REACH certification, only REACH testing, which is a test report, generally for chemicals.

The REACH test is one of the environmental tests, and substances that meet one or more of the norms stipulated in Article 57 of the Treaty can be recognized as "substances of high value" (SVHC) and included in the "Candidate List for Authorization" (also known as the "Candidate List") and arrive on the SVHC list".

It is divided into metal part and non-metal part, with 64 items for the metal part and 155 items for the non-metallic part.

2. The substances listed in the "Arrival SVHC List" are as follows:

1.Substances that meet the classification specifications of carcinogenic, mutagenic or repeated toxicity (CMR) category 1 or 2;

2.persistent, bioaccumulative and toxic substances; or very persistent and bioaccumulative (VPVB) substances;

3.There is evidence of substances of similar concern, such as endocrine disruptors.

3. What is the purpose of REACH testing?

1.Submit information on hazardous chemicals.

2.Assess and manage the hazard of chemicals.

3.Register the chemical for all purposes.

4.Substances that are less harmful to health.

5.Substances that are less harmful to the environment.

6.Support EU authorities to take faster action on the risks and hazards of chemical use.

7.Improving the competitiveness of EU chemical companies will be a good medicine for economic development.

8.Development of methodologies for the assessment of hazardous substances.

9.Ensuring the free movement of substances in the EU internal market.

It mainly controls plastics, leather, and textiles.

REACH stipulates that chemicals should be registered. To register, the first step is pre-registration, followed by formal registration.

For pre-registration, businesses in Europe are free; Non-EU companies need to pay a small fee to the ** institution, such as in China, which is generally 3,000 yuan.

For formal registration, the fee is administrative fee + data fee + ** fee, where the administrative fee and data fee are the same all over the world. The fee depends on the difference between the institutions.

Of course, it is more reasonable for European companies to do it, after all, the REACH regulation is a regulation of the European Union, and Chinese companies have no regulatory obligations.

However, often European companies will require Chinese companies to register, otherwise they will not buy your products, so there are many Chinese companies to do formal registration.

However, from another point of view, REACH is both a barrier and a business opportunity. After completing the formal registration, European customers will give priority to cooperating with you, and if they do not complete the formal registration, they may have to give up the European market in the future.

Legal analysis: REACH regulation is a regulation on the registration, evaluation, authorization and restriction of chemicals, a regulation of the EU for the preventive management of all consumer goods entering its market, a basic clause and general clause of the EU's environmental protection requirements for consumer goods, and a passport for export to the EU. For the control of the restrictions of the REACH regulation, enterprises need to correctly understand the control scope of different provisions of the slip restrictions in combination with the product and restriction clauses, and fulfill the responsibility of the restrictions, so as to avoid penalties such as recall, destruction, and withdrawal from the market after the products are put on the EU market.

Legal basis: EU 1907 2006 EC "On the Registration and Evaluation of Chemicals". Authorization and Restriction Regulations》 1. Main content Registration All chemical substances with an output or import volume of more than 1 ton next year need to be registered, and chemical substances with an annual output or import volume of more than 10 tons should also submit a chemical safety report; Evaluation includes dossier evaluation and substance evaluation.

Dossier assessment is to verify the completeness and consistency of the registration dossier submitted by the enterprise. Substance assessment refers to the identification of the risk of chemical substances harming human health and the environment; Authorization authorizes the production and import of chemical substances with certain hazardous characteristics and arouse people's attention, including CMR, PBT, VPVB, etc.; Restriction restricts the production or import of a substance within the EU if it is considered that the manufacture, placing on the market or use of a substance or its preparation or article results in a risk to human health and the environment that cannot be adequately controlled.

After receiving the reply from upstairs, he explained what pre-registration is, and I will tell you what post-pre-registration is. Post-pre-registration is ECHA to help those companies that missed the pre-registration, for example, some companies produce silica, but they only exported to the EU in 2009, in order to allow these companies to enjoy the treatment of pre-registration, therefore, ECHA allows them to pre-register, but because the deadline of December 1, 2008 has passed, it is called post-pre-registration.

Post-pre-registration has the same conditions as pre-registration, but substances classified as CMR substances (reproductive toxicity) and substances with more than 100t annual export volume of R50 53 substances (aquatic toxicity) can no longer be post-pre-registered, and these substances must be registered before they can be exported; In addition, according to the size of the tonnage, the deadline for registration is also different, the year before the deadline can not be pre-registered, can only directly prepare for the registration work, in other words, if your product is an ordinary substance, the export volume is in the range of 100-1000t, the deadline for registration is June 1, 2013, in this way, after June 1, 2012, it is impossible to carry out post-pre-registration, ECHA does not accept, can only directly carry out the registration work. For specific situations, you can consult CTI Ruiou, and the maintenance fee will be waived after pre-registration. If you have a product to be exported to the EU, hurry up and pre-register it now, it may not be too late.

REACH pre-registration is only applicable to phased substances. The pre-registration requirement is completed between 12 and 18 months after the entry into force of the REACH regulation. (i.e. from 1 June 2008 to 1 December 2008).

If the pre-registration is not completed within the specified period, the company will not be able to export its products to the EU from January 1, 2009. For manufacturers or importers, there are benefits to pre-registration and there can be a transition period. Without pre-registration, the regulations do not provide for the benefits of the transition period.

The substance can continue to be manufactured or imported while they are preparing for registration. At the same time, pre-registration facilitates information sharing and avoids duplication of studies, especially vertebrate animal testing, thereby reducing business costs.

Pre-registration time period.

1.Within 12 18 months of the entry into force of the Regulation: The registrant is required to pre-register the staged substances produced or imported in quantities greater than or equal to 1 tonne per year, unless there are special registration requirements.

2.Potential registrants who produce or import more than 1 tonne of a substance for the first time 18 months after the entry into force of the regulation are required to apply for pre-registration 6 months before production and 12 months before the registration deadline.

Purpose and benefits of pre-registration.

Purpose: To achieve data and data sharing.

Benefits: Can be produced or imported within the period specified in the registration, and can be produced or imported after pre-registration, unless the registration is refused.

To put it bluntly, it is a zero-hour license for chemicals to be exported to the EU.

On June 1, 2008, the European Union came into force the "Registration, Evaluation, Authorisation and Restriction of Chemicals" Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (hereinafter referred to as the REACH Regulation). REACH regulations stipulate that all "phased substances" that meet the annual export volume of more than 1 tonne need to complete pre-registration between June 1, 2008 and December 1, 2008, and can enjoy a buffer period of 2-10 years according to different tonnages of pre-registration, and complete the formal registration before the deadline of the buffer period.

Registration, Evaluation, Authorization and Restriction of Chemicals" is the European Union's regulatory nucleus for the preventive management of citrus chemicals entering its market. It was officially implemented on June 1, 2008. The 849-page regulation took seven years to complete, making it the most complex cantonal statute in the EU's history and the most important in the last 20 years.