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Chemicals
in articles in REACH
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Commissioned by:
German Federal Environment Agency (FKZ 205 67 462/01)
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Carried out by:
Kerstin Heitmann
Ökopol GmbH, Institute for Environmental Strategies, Germany
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Duration:
July 2005 - March 2006
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| Background |
| In October 2003 the EU Commission adopted a proposal
for a new chemicals legislation called REACH. A new consolidated draft
was presented by the Council by 19. December 2005. |
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| In contrary to the current chemicals legislation Article
6 of REACH includes general requirements related to substances in
articles. Article 6 of REACH implies an obligation to register substances
in articles, if a release of those substances is "intended",
and if the substances are present in quantities totalling over 1 tonne
per year and importer/producer. If so, a complete registration dossier
for the released substance is required. |
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| Substances have to be notified (much less data than
for a registration is needed), if they are contained in those articles
in concentrations > 0.1 % (ww) and in quantities totalling over
1 tonne per year and importer/producer. |
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| The current discussion at EU-level shows that there
are doubts that the requirements of Article 6 can be implemented,
because it contains terms difficult to be interpreted by stakeholders.
In addition compliance with the requirements is regarded difficult
to control because of the high number of articles and the variety
of substances contained in these. |
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| Objectives |
| The objective of this project is to develop proposals
for definitions and interpretations of the important terms of Article
6 and to illustrate them with examples. This includes: |
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- Identification of existing experiences from the implementation
of international conventions and legislation in Europe and Germany,
from voluntary agreements and instruments (e. g. eco label like
the "Blue Angel"), from communication instruments und
databases in different industry sectors and from different actors
like industry, trade and authorities;
- Evaluation of selected experiences with regard to definitions
and interpretation of the central terms;
- Existing systems for categorisation of articles and for investigation
of substance releases from articles;
- Available methods for identification and quantification of dangerous
substances in articles and their applicability for REACH.
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| Especially for the term "article" a clear
description is needed. |
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| Based on the results of the evaluation guidance for
industrial stakeholders (article producers, importers) will be developed.
The methods and steps for identification of "intended" release
from articles are considered. Industry and trade actors will test
the guidance on its practicability. |
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| In parallel strategies for enforcing authorities will
be discussed and outlined. This implies to outline of possibilities
for an efficient inspection and the need for further instruments and
cooperation between different authorities. The existing experiences
of the authorities involved in inspection so far will be taken into
account. |
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| The guidance for industry as well as the outline for
authorities will be discussed with experts from industry, trade and
authorities. The results of this project will be fed into the EU-Project
for the development of Technical Guidance Documents on fulfilling
the requirements for articles (REACH Implementation Project 3.8).
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| Contact |
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| Dirk Jepsen |
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