REACH and its impact on electrical and electronic component exports to Europe (within REACH & Substance in Article) Shrirang Bhoot REACH Support REACH.

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Presentation transcript:

REACH and its impact on electrical and electronic component exports to Europe (within REACH & Substance in Article) Shrirang Bhoot REACH Support REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Contents REACH in brief Electrical & electronic components implicated under substance in articles Substances of concern used in electrical & electronic components Leather articles implicated & SVHC used Compliance procedures for the Indian exporters Information for Communication Summary of obligations for non-EU exporters REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

REACH - Basics Pre-registration & Registration by non-EU manufacturer through an OR Evaluation (of some substance dossiers) by the competent authorities in Member States Authorization (of some hazard substances ) by ECHA for specific use/ application Restriction on placing of very hazardous CHemical substances in the EU market REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

What is an Article "Article means an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition;" E.g. furniture, clothes, vehicles, books, toys, kitchen equipment and electronic equipment, leather jackets, leather gloves, etc. REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Electrical & electronic components - Subs in articles REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Leather Products- Subs in articles REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

REACH Requirements for Substances in Article Essentially two requirements 1. Pre-registration & Registration of substances released from the article during normal or foreseeable conditions of use provided: Release is intentional (e.g. – perfume from the eraser, perfume from scented candles) Intentional release – Deliberate and contributes to an added value of the article Substance (which is released) is present in greater than one ton in the export consignment (per annum) The substance has not been registered for that use 2. Notification of SVHC substances if: SVHC is greater than 0.1% wt by wt (1000 ppm) REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

What are SVHC Substances of Very High Concern are: PBT substances vPvB substances CMR category 1, 2 substances Substances of equivalent concern (having endocrine disrupting properties) REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Possible SVHC used in Electrical & electronic components Sr. No.Chemical NameEC number 14,4- Diaminodiphenylmethane (or methylene dianiline) Dibutyl phthalate (DBP) Cobalt dichloride Sodium dichromate, dihydrate Bis (2- Ethyl (hexyl)phthalate) (DEHP) Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified: (Alpha-, Beta-, Gamma-) hexabromocyclododecane & Benzyl butyl phthalate (BBP) Triethyl arsenate Lead hydrogen arsenate Coal tar pitch, high temperature REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Possible SVHC used in Leather Articles Sr. No.Chemical NameEC number 14,4- Diaminodiphenylmethane (or methylene dianiline) Dibutyl phthalate (DBP) Cobalt dichloride Sodium dichromate, dihydrate Bis (2- Ethyl (hexyl)phthalate) (DEHP) Anthracene Benzyl butyl phthalate (BBP) Alkanes C10-13, chloro (Short chain chlorinated paraffins) PBT REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Obligations of Indian Electrical & electronic components Exporters Exporters need to check with their suppliers if listed SVHC are present in the chemicals they purchase and use in their process. If yes, check if the content of SVHC in the component is higher than 0.1% wt/wt (1 g/kg) If > 0.1% wt/wt, Notification requirements within REACH will apply In addition, there is a duty to communicate for any supplier of an article containing a SVHC substance sufficient information, to allow safe use of the article REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Obligations of Indian Leather Exporters Tanners need to check with their suppliers if listed SVHC are present in the chemicals they purchase and use in their process. If yes, check if the content of SVHC in the leather is higher than 0.1% wt/wt (1 g/kg) If > 0.1% wt/wt, Notification requirements within REACH will apply In addition, there is a duty to communicate for any supplier of an article containing a SVHC substance sufficient information, to allow safe use of the article REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Notification Requirements to the ECHA The information to be notified includes the following: The identity and contact details of the producer The registration number (s) for the substance, if available The identity of the substance (s) like name of the substance, CAS, EINECS No, etc The classification of the substance, which will be available from the Agency A brief description of the use (s) of the substance in the article and of the uses of the article (s) The tonnage range of the substance, i.e tonnes, tonnes etc. REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Notification Deadlines For substances included in the SVHC list before 1 December 2010, the notifications have to be submitted not later than 1 June 2011 For substances included in the SVHC list on or after 1 December 2010, the notifications have to be submitted no later than 6 months after the inclusion REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Information for Communication S. NoItemExample 1.Substance nameDiarsenic trioxide 2.CAS Number Reg. No (if provided)- 4.ClassificationCarc. Cat. 1; R45; T+; R28; C; R34 ; N; R50/53 May cause cancer 5.Conc. in article1 % wt/wt Safe handlingS53, S45, S60, S61 6.Safe disposalThis article should be disposed of as hazardous waste. Please do not put it in your normal household waste REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)

Conclusion – Obligations of Indian Exporters of Articles within REACH Assess whether there will be an intentional release No (Pre-registration/Registration requirements do not apply Yes (Estimate quantity of the substance in article, if exceeding 1 ton per annum in total exports Registration requirements apply If no intentional release, assess for the presence of SVHC Supply chain communication for SVHC in chemicals used in electrical & electronic equipments SVHC present in over 1000 ppm (1g/Kg), Notify to ECHA SVHC present below one ton, duty to communicate safe use of article to buyers and downstream users REACH and ErP Sensitization workshop 9 th Sept10 (Bangalore) & 10 th Sept10 (Chennai)