Category Archives: Blog

Dutch annual inspection report (articles):

March 4, 2015
The Dutch authorities inspected mainly companies that made or marketed consumer products. Excessive levels of cadmium were found in about...
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Swedish skin-tight clothes

February 25, 2015
Kemi also examined some 110 ‘skin-tight’ clothes such as swimwear, underwear, T-shirts and sweaters. Almost half of these contained nonylphenol...
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Hazardous substances in Swedish toys

February 18, 2015
Kemi, the Swedish Chemicals Agency, inspected plastic and electronic toys. They found banned phthalates and lead in 53 out of...
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February 11, 2015
Sweden proposes to add a restriction to Annex XVII regarding cadmium and cadmium compounds in artist paints and pigments (enamel,...
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No new restriction for DINP and DIDP

February 4, 2015
ECHA has reviewed the risks posed by articles containing the phthalates DINP and DIDP. Today these phthalates may not be...
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Supply chain disruption

January 28, 2015
The European aeronautical and automotive industries are worried about disruptions in the supply chain due to non-registration of substances for...
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REACH costs in the Aluminium industry

January 21, 2015
The European Aluminium industry has studied the overall cost resulting from of EU legislation. The REACH component in these costs...
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Corrosive cleaning products in Denmark

January 14, 2015
The Danish Environment Ministry inspected over 160 cleaning products sold in DIY stores. On almost half of the inspected products,...
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Substance Identification

January 7, 2015
The European Commission is commissioning a study into the difficulties in the identification of complex substances (Mainly UVCB’s: Substances of...
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Petroleum substances

December 30, 2014
ECHA has published the results of a study into the methodologies used by industry for the environmental risk assessment of...
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Paperless Safety Data Sheets for the car industry

December 24, 2014
European, Japanese and Korean car producers, together with their suppliers are pushing a standardised data-exchange system for Safety Data Sheets...
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US EPA wants REACH data

December 17, 2014
The US Environmental Protection Agency has its eye on the data that was collected and generated for the REACH registration...
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Dutch annual inspection report (chemicals)

December 10, 2014
The Dutch authorities inspected mainly producers, importers and traders. The companies made or marketed chemicals, cosmetics, paints, adhesives, sealants, washing/cleaning...
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ECHA’s SME checks

December 3, 2014
Small and Medium Sized companies pay substantially lower ECHA fees. There are strict rules that determine whether a company is...
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Missing substance identifiers

November 19, 2014
Both in Annex XVII and in the Candidate List some entries have no CAS or EC numbers (for example: refractory...
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‘Dissenter’s Guidance for articles’

November 12, 2014
Six Member States disagree with the Commission’s interpretation of the ‘0,1% rule’ for Substances of Very High Concern in articles....
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New Guidance for Down Stream Users

November 5, 2014
The revised Technical Guidance Document for Down Stream Users is expected soon. As a last step towards its publication is...
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Updated Navigator tool

October 29, 2014
The ECHA Navigator is an interactive tool that helps producers and importers of both chemicals and articles to identify their...
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SVHC Roadmap 2020

October 26, 2014
Things seem to be moving towards industry involvement in an early stage to determine the best RMO (Risk Management Option)...
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New FAQ structure on ECHA website

October 22, 2014
All the many FAQs and Q&A-pairs on the ECHA website have been reorganised. The result is better searchability, easier linking...
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Nasty metals in Swedish toys

October 15, 2014
Excessive Cadmium, Nickel and Lead and banned Phthalates were found in toys and jewellery on the Swedish market. One third...
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France bans BPA in baby food packaging

October 8, 2014
EFSA (the European Food Safety Authority) has repeatedly studied BPA (Bisphenol A) and concluded that, at the concentrations in which...
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Notifications of SVHC in articles

October 1, 2014
When a group of articles contains more than 1 tonne and > 0,1% of a Candidate List substance, this must...
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Systematic approach to restrictions

September 24, 2014
So far Annex XVII (Restrictions to Marketing and Use) tends to be adapted in a haphazard way. The European Commission...
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Test your knowledge of the new pictograms

September 17, 2014
With GHS (Global Harmonised System) coming into force, the labels on the packaging of dangerous chemicals will be changing. There...
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Classification and Labelling Inventory

September 10, 2014
ECHA’s Classification and Labelling Inventory lists millions of different classifications for over a hundred thousand different substances. These were all...
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ECHA checks SME claims

September 3, 2014
ECHA is in the process of checking all the SME claims for a lower registration fee. If an SME claim...
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New ECHA fees

August 27, 2014
The European Commission has published a new version of the ECHA fee regulation. The registration fees for large companies have...
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Authorised substances in recycled plastic

August 20, 2014
European plastic recycling companies are worried about substances subject to authorisation in their products. These are mainly phthalates. The companies...
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More evaluations

August 13, 2014
CoRAP has been updated. This Community Rolling Action Plan lists the substances that will be evaluated in the coming years....
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The first Evaluation results

August 6, 2014
The E in REACH stands for Evaluation. The dossiers for at least 5% of all the registered substances will be...
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Results of ECHA’s Intermediate dossiers checks

July 30, 2014
Late 2012, ECHA checked some 5.500 dossiers for intermediate registrations. Intermediates are substances that are only used to manufacture other...
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On-line translations for REACH terminology

July 23, 2014
The terminology used in the world of REACH and related legislation is complex to say the least. The fact that...
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ECHA for the general public

July 16, 2014
The ECHA website has a section aimed at the general public: ‘Chemicals in our Life’. It provides information about the...
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ECHA on Twitter!

July 9, 2014
ECHA, being a young organisation, now has a Twitter account. ECHA will tweet information about press releases, news alerts, public...
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The SIN List is back

July 2, 2014
The SIN List (‘Substitute It Now’) contains more than 600 substances that, in the opinion of NGO’s and a few...
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ECHA’s PBT assessment confirmed

June 25, 2014
ECHA identified anthracene oil, anthracene oil (low), anthracene oil (paste), and coal tar high pitch as PBT (Persistent, Bioaccumulative, Toxic)...
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Plans for the Candidate List

June 22, 2014
ECHA published a roadmap for ‘completion’ of the Candidate List of Substances of Very High Concern. By 2020 all the...
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Labelling and packaging guidance

December 5, 2012 Tags:
ECHA has published a new Technical Guidance Document on Labelling and Packaging. The document replaces a few sections from the...
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Mixtures of concern

November 28, 2012 Tags:
Today the dangers of mixtures to human health or environment are assessed on the basis of the toxicity of the...
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RIPE is ripe

November 21, 2012 Tags:
RIPE is a web-based application that is available since this summer to the EU REACH enforcement authorities. It gives them...
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New EU toy safety directive

November 14, 2012 Tags:
The new EU toy safety Directive 2009/48/EC came into force in July 2011. The new directive applies to all toys...
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November 7, 2012 Tags:
The plans for the evaluation of the registration dossiers are being developed further. Some 5% of the dossiers will be...
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Nano-material definition

October 31, 2012 Tags:
The European Commission has adopted an official recommendation for the definition of nano­materials.  They recommend that Member States and EU...
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Are Nano-materials articles?

October 24, 2012 Tags:
An interesting legal point of view regarding Nano-materials circulates in industrial circles Brussels. The view is that under REACH, nano-materials...
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Invalid pre-registrations

October 17, 2012 Tags:
ECHA has removed more than 40.000 invalid pre-registrations from their records. Some of these removals were requested by the pre-registrants...
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ECHA action on multiple registrations

October 10, 2012 Tags:
Potential REACH registrants are supposed to cooperate in SIEFs (Substance Information Exchange Forum) and share data where possible. As a...
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Custom supervision exemption clarified

October 3, 2012 Tags:
Substances under customs supervision do not need to be registered. As always, such a simple rule does not work in...
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New ECHA factsheet incomplete and too complicated

September 26, 2012
The new ECHA factsheet on the ‘supply chain communication for exempted substances’ is a missed opportunity. Important exemptions are not...
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Authorisation procedure

September 19, 2012 Tags:
A permit for the use of substances in Annex XIV (subject to Authorisation) can only be obtained for specific uses....
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Registration of intermediates

September 12, 2012 Tags:
Intermediates are substances that are only used to produce other substances. Some are never even isolated from the chemical process;...
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Substances in stock

September 5, 2012 Tags:
Can pre-registered substances, that were manufactured or imported before the registration deadline, be placed on the market after that deadline,...
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August 29, 2012 Tags:
Intermediates are substances that are used solely to produce other substances. They require a smaller registration dossier than other substances...
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Who is the importer?

August 22, 2012 Tags:
At Sitmae, we have customers with complicated supply chains in the EU. Some have agents and others have large warehouses...
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Obligation for substances in articles

August 15, 2012 Tags:
From June 1st 2011 a new obligation kicks in for articles that contain Candidate List substances. In some cases, the...
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‘Extended’ Safety Data Sheets and mixtures

August 8, 2012 Tags:
Now that new Extended Safety Data Sheets for substances come available, the SDS’s for mixtures may have to be adapted....
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New Safety Data Sheets

August 1, 2012 Tags:
Companies that have registered a substance must now adapt their Safety Data Sheets. The results of the Chemical Safety Assessment...
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How registration works

July 25, 2012 Tags:
The consortium The complex registration dossiers are generally prepared by a consortium. A consortium is a group of European manufacturers...
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Registrations in a non-EU supply chain

July 18, 2012 Tags:
Non-EU formulators (producers of ‘mixtures’) may purchase substances that have already been registered by their non-EU supplier. Or they may...
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Next registration deadlines

July 11, 2012 Tags:
No news, but an important reminder: the next registration deadlines are the following: Substances marketed between 100 and 1.000 t/a:...
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Big difference in national REACH fines

July 4, 2012 Tags:
The Commission study comparing penalties for non-compliance with REACH was finished end 2009. The most common form of sanctions are...
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CLP notification and imported substances

June 29, 2012 Tags:
According to the CLP regulation (Classification, Labelling and Packaging of chemicals) all manufacturers and importers of chemicals must notify to...
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Registration of alloys and intermetallic compounds

June 20, 2012 Tags:
According to REACH, alloys are ‘special mixtures’. They are to be treated in the same way as other mixtures under...
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Registration of monomers

June 13, 2012 Tags:
Polymers are exempt from registration under REACH. The monomers that were used for their production are however not. In the...
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SME’s must prove their ‘smallness’

June 6, 2012 Tags:
SME’s (Small or Medium sized enterprises) pay lower fees to ECHA than larger companies. Where registrants claim to be SME’s,...
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New guidance on waste and recovered substances

May 30, 2012 Tags:
The new guidance is for companies who recycle and recover. Substances that are recycled or recovered in the EU often...
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May 23, 2012 Tags:
The discussion on the REACH definition of ‘importer’ seems to come to a reasonable conclusion. According to REACH the importer...
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Substances in Articles

May 16, 2012 Tags:
When candidate list substances occur in articles in a concentration higher than 0,1%, this has to be declared to the...
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May 9, 2012 Tags:
Possibly the most frequently asked question to Sitmae consultants is whether candles are articles or preparations. The difference is of...
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Communication on uses

May 2, 2012 Tags:
Important features in the Registration dossiers are the Exposure Scenario’s. For every use of the substances there must be a...
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Recovered substances

April 25, 2012 Tags:
Substances that are recovered in the EU do need not be registered again; provided that they have already been registered...
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Toll manufacturing

April 18, 2012 Tags:
In some industries it is usual to job out the production of substances to others; the so called ‘toll manufacturers’....
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Registry of intentions

April 11, 2012 Tags:
This Registry provides information on the intentions of the Member States to submit proposals for harmonised Classification and Labelling of...
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Non-EU supply lines

April 4, 2012 Tags:
Importers of non-EU produced formulations and the Only Representatives of non-EU based formulators have pre-registered the substances in the imported...
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New REACH deadline ahead

March 28, 2012 Tags:
A little known REACH deadline for pre-registrations is coming up: less than two months to go! As every REACH follower...
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