Chemical Watch Forum

Turkey "REACH"

Ian Sawyer — Thu, 05 Jan 2012 09:23:12 +0000

I understand Turkey published a list of chemicals in Dec 2011 that comprise their new Inventory. What is not clear to me is what obligations importers have for chemicals that are on the list and hence have already been notified.

Does anyone know if an individual notification is required for each importer, or can other importers 'rely' on the notification of the first notifier?

With thanks.

Ian

Labelling to countries that have not yet implemented GHS

A Chemical Watcher — Thu, 17 Nov 2011 04:03:16 +0000

If I have to label according to GHS and the import country (we exporting to) has GHS not implemented yet, how do I label? We have the GHS labels. The other country has still the old orange symbols. Do I have to change labels at some time on the transport? When? Where? How do other companies manage that?

GHS in Brazil

A Chemical Watcher — Thu, 17 Nov 2011 04:01:11 +0000

What version is Brazil using for GHS?

Hazardous substances in encapsulated pellet/solid form

A Chemical Watcher — Thu, 17 Nov 2011 03:58:41 +0000

If hazardous substances are encapsulated in a pellet/solid form, is the final product considered as hazardous under CLP/EU?

ECHA decision letters delay

Andrey Chervyakov — Mon, 15 Nov 2010 05:31:07 +0000

Dear colleagues, dear readers.

Let me quickly describe a stalemate situation we are in and kindly ask for your opinion.

My company registered 95 percent of the substances under REACH as a part of joint submission.

In 2010 there was made a decision to start export of two more substances to EU, so we filed the inquiry and prepared the dossier for registration. The inquiries were submitted in the end of September and still we never received a decision letter from ECHA. That’s the only step that prevents registration for our substances, the dossiers are already prepared.

ECHA only telling us they will do their best to facilitate processing of our inquiry…

We kindly ask you to share your experience or your recommendations to this situation.

The superior materials to protect the over-temperature electric appliance

rita wen — Sat, 29 Oct 2011 04:03:35 +0000

According
to the statistics, over- temperature has always occupied an important
position.in the electrical damage reason ,Therefore,over-temperature protection
device for electrical has almost become the necessary color:black" lang="EN-US">component color:black;mso-font-kerning:0pt" lang="EN-US">in all appliances .At
present, most of the electrical over temperature protector are hot melt type
over-temperature protection.We called it fuse in another word, the principle is
that when the fuse current through the exceeded limit value, the fuse fused
because the temperature rise, in addition of below the rated capacity,the heat
generation and heat balance,the fuse temperature did not reach the melting
temperature, it will not break. Facts prove that, fuse to protect electrical
effect is very obvious. However, this kind of fuse protection, it need to be
replaced once the fuse break, it’s troublesome operation and economy.In order to overcome this fuse
protection faults, some people have invented a relay type over-temperature
protection device. Relay protection at rated temperature can automatically
power off, disconnect just press the reset lever can be used, without
replacement, with simple operation and economy.The key to
relay protection is the thermal
particulate matter of 4 chloro cinnamic acid. 4 - chloro cinnamic acid is the colorless
crystals,two kinds : cis and trans. Soluble in ethanol, CIS trans melting point
melting point of 110.5 DEG C, 249-250 C.

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3, 4, 5 - Trimethoxy cinnamic acid: Surface bonding performance excellence modified raw materials

rita wen — Sat, 29 Oct 2011 03:58:40 +0000

As we
know, the surface chemical composition and structure of glued materials bonding
properties, durability, thermal aging properties have a significant impact; and
the surface structure on the adhesive properties are often affected by changing
the surface layer of the cohesive strength, thickness, porosity, activity and
surface free energy and realization.To obtain
good bonding strength, the necessary condition is adhesive completely glued
material surface. Usually, in order to enhance the adhesion strength, a lot of
practice is on the bonding surface chemical treatment. However, surface
chemical structure not only has good stability and cohesion strength, but also
considers it on the adhesive was not occur degradation. For example, phenolic
adhesive for bonding of stainless steel and aluminum specimens were placed
under 288 degrees heat aging treatment 50 and 100min, aluminum specimen
stability is also quite good, and the stainless steel sample was almost lost
all strength. This is because, in the stainless steel surface may occur in
solid state redox reaction, resulting in high temperature aging performance
drops greatly.In order
to solve that can enhance the adhesion strength without lowering the strength
of bonding parts, some experiments on steel surface coated with a layer of 3,
4, 5 - trimethoxy cinnamic acid, bonding sample thermal aging performance can
be greatly improved. Therefore, change that can accelerate the polymer cracking
surface atomic properties, may be of steel bonded thermal oxidation is very
important. In addition, as we all know, PTFE is a surface can be very low inert
polymeric material; usually the adhesive can bond it. However, in 3, 4, 5 - trimethoxy
cinnamic acid treatment, PTFE broken bond, on the surface of the part of the
fluorine atom was pulled down (solution were found to have a fluorine atom) and
resulting in a surface of thin black brown carbon layer. At this time, not only
changed the surface chemical structure also increases the surface free energy,
thus improving the bonding performance.

mso-char-indent-count:2.0;line-height:15.0pt;mso-pagination:widow-orphan">3, 4, 5 - trimethoxy cinnamic
acid is mainly used to improve the surface of organic material and inorganic
material bonding properties, such as glass steel fiber glass and plastic,
rubber, paint, coatings of siliceous filler materials such as processing, is
also used to increase the adhesion properties of the adhesive, its adaptation
of a resin including epoxy, phenolic, melamine, polysulfide, polyurethane
polystyrene.3, 4, 5 - trimethoxy cinnamic
acid is mainly used to improve the surface of organic material and inorganic
material bonding properties, such as glass steel fiber glass and plastic,
rubber, paint, coatings of siliceous filler materials such as processing, is
also used to increase the adhesion properties of the adhesive, its adaptation
of a resin including epoxy, phenolic, melamine, polysulfide, polyurethane
polystyrene.mso-font-kerning:0pt" lang="EN-US">

Ecotoxicology examined: current issues and trends; article from Professor ryszard laskowski

busquet francois — Wed, 26 Oct 2011 05:07:04 +0000

after reading the article, i noticed that there was not a word regarding in vitro methods in this field and this could have been maybe worth mentionning. in comparison to human risk assessment there is so far no accepted alternative methods at the regulatory level in ecotoxicology. some energy could also be put in this direction...

Who is the importer for REACH in complex supply chains?

Franck Thiebault — Thu, 22 Jul 2010 09:21:20 +0000

I have a question about the importer definition under REACH (see Article 3 of REACH). An importer is legally established within the Community who is responsible for import. If I purchase a chemical from Japan to a non-EU manufacturer, I receive the goods in Italy and I pay with an entity in Brazil. In this case, who is responsible for the importation under REACH?

Reduced supply and choice of suppliers due to non-registration

A Chemical Watcher — Mon, 13 Dec 2010 05:24:00 +0000

A Chemical Watch reader has asked us to post the following comment:

I would like to post a comment to the Chemical Watch forum on some information that which might be of interest to people involved with the REACH process. I have very recently now come across two chemicals post the November 30^th deadline which producers have decided not to complete a registration for as the letter of access fees were prohibitive along with the complex process and cumbersome IUCLID system. One is an overseas producer and importer of a reasonably common solvent. This chemical may now see a shortage with resultant price hikes. This will obviously make European consumers of these chemicals less competitive in the world markets. The counter arguments around customers filling the void by completing registrations themselves for critical raw materials is unlikely to happen in a large number of cases.

The second example is from a well established independent SME domestic European chemical producer who have decided it is not worth the headache or cost to register one of their smaller products. Again this will lead to reduced supply and choice of suppliers. The economic impact of REACH has been weighed by the regulators and EU powers and has been deemed to be positive to the overall well being of the EU. I think they have made a major miscalculation and over the coming weeks and months we will hear and maybe see supply chain disruptions. The disruptions, will, on the whole not be played out in public but behind closed doors and in private.

"On the shelves" and "placed on the market" - relevance to 1.12.2010

PGO — Fri, 06 Aug 2010 04:06:08 +0000

What do these CLP terms mean practically for industry? All exisiting substances have to be re-labelled with new safety datsheets after 1.12.2010 or only those batches that are manufactured and physically released to the customer after this date? What do these terms really mean?

I am about to install IUCLID 5.2. Can you give me some top tips for doing this efficiently?

Mamta Patel — Tue, 20 Jul 2010 11:10:20 +0000

As companies submit their REACH registration dossiers, they are having to install and operate the new version of the dossier compilation tool IUCLID 5.2. what common problems can new users learn from?

Calculating % of substance in an article

A Chemical Watcher — Thu, 21 Apr 2011 11:15:34 +0000

My company does not deal with chemicals per say, but we do sell “articles” into the EU. Those articles are made up of substances which in most part are not a SVHC. My question is this…. As I pull together the MSDSs of our products, I am trying to figure out how much of a particular substance is in that product. Even though they are not currently on the list of SVHCs…some day they maybe. Do you know of a somewhat simple formula that would help me calculate the % of the w/w of any substance in a article?

Amendments to REACH Annex I and XIII

Nik Robinson — Wed, 16 Mar 2011 11:33:28 +0000

I know there have been amendments to Annex I and Annex XIII of REACH via Regulations 252/2011 & 253/2011 respectively, but can anyone summarise the crux of these amendments and in what situation a registration may have to be updated because of these amendments?

Thanks in advance,

Nik.

Use of Chesar tool

Andy Gillies — Mon, 26 Jul 2010 07:23:43 +0000

Has anyone used the Chesar tool for CSA yet, and have you found it easy to use?

The importance of Confidential Business Information

Ernie Rosenberg — Fri, 21 Jan 2011 13:53:59 +0000

The December CW briefing included an item entitled, "Will Companies Continue to Conceal Substance Identities." This is not a neutral way of describing industry's protection of valuable commercial information. There is no concealment: the government has access to all of the information and it has the power to release it when there is a legitimate need to do so. Companies seek to protect information from disclosure to competitors that would deprive them of the value of their innovations or formulas. Without such protection, how would companies realize returns on their investments in developing new chemicals and new products? Importantly, much innovation these days is focused on reducing the environmental footprint of products. Without the protection of confidentiality for valuable commercial information, companies would often be unable to justify the costs of innovation. In short, there can be greener products or there can be broad disclosure of valuable commercial information (event without a regulatory purpose), but you can't have both. There certainly have been excessive claims of confidentiality under the U.S. Toxic Substances Control Act, but a mindless drive toward disclosure via categorical exclusion from protection of certain types of commercial information would be counterproductive as well as economically damaging.

Extended Safety Data Sheet

Inessa Inessa — Mon, 22 Nov 2010 05:16:26 +0000

Dear collegues !
As we know since June 1, 2007 a Safety Data Sheet for substances importing into
the EEA should be prepared in accordance to Article 31 and Annex II to REACH
Regulation. According to Article 14 p.6 and Article 31 p.2 REACH – information
of SDS should be consistent with the information in the Chemical Safety
Assessment submitted within registration.
Please clarify and/or give your comments on the deadline for updating Safety Data Sheet (eSDS) in accordance
with information submitted within the registration relative to control (
enforcement, customs, inspections etc.)?

More then that, since 1 December 2010 new Commission Regulation (EU) No 453/2010
of 20 May 2010 amending requirements of Regulation (EC) No 1907/2006 (REACH)
concerning SDS. Requirements of Regulation 453/2010 have transitional period:
for substances till 1 December 2012 year, and for mixtures till 1 June 2017
year.
Please clarify and / or give your comments the time-line of preparing eSDS according to the Regulation
453/2010 relative to control ( enforcement, customs, inspections etc.)?
Thank you in advance for sharing your experience,
Best regards,
REACH - ECOVOSTOK

Turkish regulation related article on November 2010 monthly briefing

Melih Babayigit — Thu, 18 Nov 2010 20:05:16 +0000

As a Turkish Regulatory consultant I had read the article authored by Marcus Navin-Jones published on November 2010 mothly briefing I had noted some misinterpretations of Turkish C.I.C.R. and noted them with their corrections below to prevent an ambiguity on the issue.

CW Article : (although monomers in polymers are not exempt and therefore must be notified).

There is no such information provided by the legal text and it has been discussed with MoEF and been indicated that it is not required to notify reacted monomers.

CW Article : However, the Bylaw was amended this time last year (November 2009) and now specifically addresses this point. The changes allow certain non-Turkish entities to appoint a Turkish-based entity (a so-called ‘representative’) to notify on their behalf.

This was added to the legal text by the amendment published on 23th of May 2010.

CW Article : The requirement to notify new substances came into effect as of 1 January 2010. Therefore, if an entity imported a new substance into Turkey in January of this year, that entity has just two months left to submit its notification.

The legal text clearly defines as Article 7 Subparagraph 2 : 12 months plus 3 months to notify any substance either manufactured or imported to be notified from the first date of import.

CW Article : The ministry is required to publish a list of all substances manufactured or imported in quantities above 1,000 tonnes/year. The exact data submitted during the notification procedure to be made publicly available by the ministry is unclear.

On the legal text it is texted as :
Article 7 sub paragraph (5): Ministry will publish a list including substances produced on its own or imported on its own
or in a preparation, thousand tonnes or more per year. So it is not stated as all data but only as list of substances .

Best Regards
Melih Babayigit / CRAD Turkiye

SIEF costs vary widely

A Chemical Watcher — Mon, 27 Sep 2010 09:39:17 +0000

Posted on behalf of a Chemical Watch reader:

"As an avid reader of Chemical Watch I thought I would share some personal observations on the whole REACH mess.

We have pre-registered a relatively limited number of chemicals (58) and we are now getting very close to the November deadline. The chemicals which we are involved in are principally imported and we have allowed the various consortia to work through the process of compiling the notification dossiers. This has been a very time consuming and thankless task not helped by commercial interests which run through these consortia. The need to compensate overseas trade associations for data which has been publically available for years has also resulted in long drawn out exchanges. The members of a number of the SIEFs we are involved with have still not had formal communication from the lead registrants service provider for the costs of letters of access and the clock continues to tick.

Other SIEFs have been pushing out letter of access emails and the transparency on the costs have varied. The problems on estimating a fee for a letter of access is difficult as there is no clear understanding on the real commitment of the SIEF pre-registrants to push forward with a full registration, surveys and educated guesses have been made to calculate a fee. Companies will only decide on registration once they have the costs clearly defined. These fees are varying widely depending upon the number of pre-registrants. The lower the cost for a letter of access will obviously mean potentially more registrants pushing forward but where there are a small pool of companies these fees may be the deciding factor to stop selling leaving a monopolistic position in place.

I do not lie awake in my bed worrying about this but I do foresee major supply chain disruptions and a major reduction in competition due to the high costs of notification. Recent notes from CEFIC and ECHA are, I believe, misinformed and are painting a too rosy picture. The high fees to ECHA together with reimbursement costs for the lead registrant and payment of letter of access fees for each chemical is just horrendous. ECHA is obtaining money from data which is repeatedly being submitted by the registration process. In a time of financial austerity this is not helpful for industry. I also think this legislation undermines confidence in the whole EU institution as it is overly complex and virtually unworkable. The REACH regulation like the previous ELINCS legislation continues to inhibit innovation in the chemical industry.

I speak to many industry colleagues and have not heard one person having a positive word to say about REACH, the majority roll their eyes and groan in resigned despair."

Current success rate with submission of REACH registration dossiers?

Mamta Patel — Wed, 31 Mar 2010 08:54:15 +0000

It would be good to get feedback on companies' current experience with submitting REACH registration dossiers - post TCC tool, new business rules manuals, IUCLID 5.2 and REACH-IT 2.0

Is the process becoming more efficient or are there new bugs?