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REACH registration figures confirm the leading role of the Belgian chemical sector

Producers and importers of chemical substances have already submitted over 51,000 REACH registration dossiers to the European Chemicals Agency (ECHA). 7% of these dossiers came from Belgium. In concrete terms, this means that, in total, the Belgian industry submitted around 2,967 registration dossiers for 1,568 substances, and paid ECHA 48 million Euros in fees. This data can be found on the ECHA website.

One third of Belgian registrations was performed by the ‘Only Representative’ of a non-European company. It is to be remarked that Belgian branches often take responsibility for the registrations of their non-European mother company or subsidiaries. Only the United Kingdom surpasses Belgium in this:  41% of British registrations come from ‘Only Representatives’ which are often consultants.

In 16% of the Belgian dossiers submitted, a Belgian company takes the leading role as ‘Lead Registrant’. This is comparable to the numbers for the French industry. Only Germany precedes us, with 25% lead dossiers in the total number of German registrations. These figures confirm the leading role of the Belgian chemical industry in Europe.

The annual essenscia survey shows that once a chemical substance has been included in the candidate list of substances of very high concern**, companies consider stopping using this substance or replacing it with a safer alternative. At the beginning of 2015, around half of respondents reported that they produced, imported or used at least one of the 163 substances mentioned on the candidates list. One fifth of respondents does the above with a substance which is subject to authorisation. This concerns a total of 33 substances.

*echa.europa.eu
** echa.europa.eu/web/guest/candidatelist-table

Sector initiatives

REACH also applies to nanomaterials

productveiligheid nanomaterialen

For maximum transparency in information regarding nanomaterials

The European Commission evaluated the legislation on nanomaterials at the end of 2012. Although the Commission deemed the current regulations to be sufficient for informing users of the risks of nanomaterials, a number of extra measures were still put in place. These concerned:

  • the clarification of the guidelines for registering nanomaterials under REACH (Registration, Evaluation, Authorisation and restriction of Chemicals). A proposal linked to the clarification of tests contained in the REACH appendices is expected in the course of 2015. Meanwhile, ECHA (European Chemicals Agency) is adapting the guidance documents with a view to the registrations in 2018.
  • even more transparency in connection with the information available on nanomaterials. In 2014 the European Commission held a public consultation on the possible policy options. The final decision is not yet available, but is expected in 2015.

October 2011 saw the first definition of nanomaterials by the European Commission. It concerned Recommendation 2011/696. This definition is currently under evaluation by the Joint Research Centre (JRC).

What are the most important challenges?

  • identification of accepted and validated methods and means to measure and analyse nanomaterials;
  • refining of methods to evaluate the degree of exposure to nanomaterials;
  • completing of existing information with the dangers which nanomaterials involve, but also on classification, labelling and packaging (CLP).

In the context of these challenges, the chemical industry is collaborating on various research projects, including those under the Organisation for Economic Co-operation and Development (OECD).

essenscia argues for an approach at the EU level

Nanotechnology and nanomaterials offer solutions for a plethora of worldwide issues such as sustainable energy, public health and water supplies. However, society has many doubts about the safety of these products.

Nevertheless, nanomaterials are just like any other material: some materials are toxic and some are not. Thus these materials must be registered under REACH and therefore there is a need for safety data sheets and specific procedures for the classification and labelling of dangerous nanomaterials.

Some European member countries (like Belgium) have already implemented a mandatory registration of nanomaterials. essenscia holds the opinion that the need for transparency requires a Europe-wide approach. For in this way interpretation problems between the member countries and a disrupted market can be avoided.

The mandatory Belgian registration essentially requires that materials in a nanoparticle state that are to be brought onto the Belgian market must be registered in the national register before 1 January 2016. Mixtures containing nanoparticles must be registered before 1 January 2017. Registrants are obliged to inform their professional clients of this Belgian registration number.

The complete European Commission evaluation of the legislation concerning nanomaterials is available on the following websites: www.eur-lex.europa.eu.

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REACH: A need for a scientific approach on endocrine disruptors

productveiligheid REACH hormoonverstoorders

What are endocrine disruptors?

Within the European Union, currently no definition exists for ‘endocrine disruptors’. At the moment, the definition as determined by the World Health Organisation in 2002 is used: ‘an endocrine disruptor is an exogenous substance or mixture that alters function(s) of the endocrine system and consequently causes adverse health effects in an intact organism, or its progeny or (sub)populations.’

To define which substances are endocrine disruptive, it is essential that some criteria are specified. This process is still ongoing. For the industry it is important that this is clarified as soon as possible. Concerning the criteria, it is important to make a clear distinction between hormonally active substances – these are substances that are secreted by our metabolism before any damage is done – and substances that have a negative effect on a healthy organism or a population.

Europe is already taking steps

Where do we stand today? The European Commission has prepared a roadmap. This is a step-by-step plan in which the policy on endocrine disruptors is developed. Meanwhile, a number of legislations already includes measures in respect of endocrine disruptors. This is already the case for the legislations on pesticides, biocides, REACH.

In the existing REACH legislation endocrine disruptors are viewed in the same way as other substances of concern. Specific reference is made to carcinogens, mutagens and reprotoxic substances are referenced. In 2014, five substances on the candidate list for authorization were identified by the expert committee of the Member States for the first time. They were described as endocrine disruptive and harmful to the environment. For all of these substances, limitations or a ban on use were already in place (unless authorization was obtained).

Currently, about 29 substances are being evaluated in terms of potential endocrine disrupting properties through different REACH processes. When considering additional measures for these substances, it is important that factors such as the exposure to and the potency of these substances are considered.

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essenscia helps SMEs in implementing chemicals legislation

productveiligheid VLARIP WALRIP NL-02 productveiligheid VLARIP WALRIP NL-03

essenscia guidance projects are still a success

Since 2007, essenscia has been guiding SMEs in applying REACH and CLP, the mandatory information and communication concerning risks and hazards of chemical products.

For this purpose essenscia has set up two regional projects:

  • Flanders REACH Implementation Projects (VLARIP) and
  • Wallonia Reach Implementation Programme (WALRIP)

In both projects exchanging experiences is a key element.
Among other things, the projects support SMEs with:

  • REACH registration deadlines and other REACH obligations
  • creating safety data sheets for users
  • classifying dangerous substances and mixtures according to CLP
  • obligations for nanomaterials.

Every year 45 companies actively participate in VLARIP, supervised by 11 sponsor companies, while 70 companies took part in WALRIP. The evaluation of these two projects revealed considerable satisfaction among participants.

essenscia also collaborates with Fedustria and Centexbel in the TEXCHEM project for the sustainable and safe use of chemical products in the textile sector, with 40 textile companies and their suppliers participating.

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essenscia shares its knowledge

essenscia shares its knowledge

The essenscia product policy team organises training sessions on obligations when marketing chemical products.

Amendments to legislation and staff changes create the need for reliable and regular training. The product policy training team focuses in particular on training on chemical legislation (amended or otherwise) with little or no commercial availability.

The following trainings are provided:

  • What chemical products to register according to REACH? How to label and package hazardous substances? How to edit a safety data sheet? What rules apply when transporting dangerous substances?
    All of this is offered in the basic training on product policy.
  • The current state of affairs is examined during the annual study days. These information and networking sessions always attract around 100 interested parties from the industry and government.
  • Every year, 150 companies take part in the thematic regional breakfast sessions.
  • For the last two years, 83 employees from 66 companies have taken part in the annual five-day training on Classification, Labelling and Packaging (CLP) of dangerous substances and mixtures. Due to the large demand, this training was even organised three times in 2014. The course was realised in collaboration with Ghent University and other knowledge centres, and provides more background and insight into the different tests and criteria for CLP classification and labelling.

These trainings are open to everyone, and in 2013 and 2014 essenscia thus reached 902 participants.

essenscia’s experts also make their expertise available to other training providers, with around 20 training session provided for 362 participants at 10 external training providers in the last two years.

The training team is recognised with the Qfor quality label since 2010, and is an accredited training provider for the SME portfolio. This was successfully extended in 2013, and also extended with training organised by the social department. The course is also eligible for reimbursement of employees’ training costs through Co-valent.

The essenscia training team’s calendar is available at www.essenscia.be/nl/opleidingen

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PhytoTrans An essential tool for the safe distribution of plant protection products

Productveiligheid REACH PhytoTrans-02   Productveiligheid REACH PhytoTrans-01

Phytofar* has provided an internet tool for the use of the distribution sector since 2005, called ‘PhytoTrans’. This tool supplies downstream users with useful information on the necessary documents for the packaging and transport of phytopharmaceutical products and also makes these transport documents available per product. Information is given on the criteria to be met by transport documents and safety data sheets (SDS). As a result this tool helps to meet the REACH requirements.

The content is kept up to date by members who have authorization to work with these products. That is to say, all members of Phytofar, but also non-members who strive to comply with the service level agreement. This tool and the complete list of organisations with authorization to work with these products can be consulted on the Phytofar website.

Today this tool is recognised by the professional distributors of plant protection products. In the future other downstream users will also gain access to the SDS data made available through PhytoTrans. This service will also be offered on the Phytofar website.

Phytofar’s web tool comes at a very opportune time given that the plant protection products market will be officially divided into professional and non-professional sections from 25/11/2015. This instrument will undoubtedly contribute to a coherent information and communication strategy.

*Phytofar: the Belgian Association of the Plant Protection Products Industry

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