Implementation of the EU's chemical regulatory system

"If a shirt is marked with '23% of the material is unknown', will you still buy it?" A few days ago, the European Women's Organization is advocating: The customer has the right to know the chemical composition of the product.

This activity is the response of European non-governmental organizations to the European Union's chemical regulatory system. The "Registration, Evaluation, Management and Restriction of Chemicals" (hereinafter referred to as "REACH") will be formally implemented on June 1.

The Act requires that all products exported to Europe must be declared to contain chemical components, and if they cannot prove their safety, they cannot qualify for market access.

Pan Yangshuo, deputy secretary-general of the Export-oriented Chamber of Commerce for the Import and Export of Shoes and Caps of Fujian Province, said that the REACH regulation is currently the most stringent and most complex non-tariff regulation. Exports of chemicals, household appliances, textiles, toys, and pharmaceutical products will all be affected.

Pan Yanglu introduced that this 800-page-high number of English specialty chemicals laws and regulations, high technical content, but there is no reference to the implementation details, so that Chinese companies can not start.

Minmetals Chemicals Import and Export Chamber of Commerce Petrochemical Department Xiong Yu introduced that in 2001, the EU began to brewing this legislation, was known as the "European Chemical Strategy White Paper", published on the EU official website on December 30, 2006, 6 in 2007 It will come into effect on the 1st of the month and will be implemented on June 1st, 2008.

Xiong Hao introduced that Minmetals Group, Sinopec and other large-scale chemical producers have relatively large exports to Europe each year, and they have set up special departments or sent personnel to follow REACH regulations. However, a considerable number of SMEs take a wait-and-see attitude. Some simply decide not to export to Europe.

Since the beginning of last year, the Ministry of Commerce, local commercial offices, and related industry associations have started access to the REACH regulations. Organizations such as the Fujian Federation of Importers and Exporters of Shoes and Caps and the China Textile Industry Association have started to introduce and train enterprises to respond to the REACH Act.

Minmetals Chemicals Import & Export Chamber of Commerce is the only REACH Regulation Consultation Service Center authorized by the Ministry of Commerce. At present, there are a total of three domestic agencies that specialize in providing consulting services for REACH regulations. The other two are the China Inspection and Quarantine REACH Resolution Center and China Chemical Network under the AQSIQ.

According to regulations, two procedures for pre-registration and formal registration of China's exports of EU goods are required. Exporters of finished products such as clothing and toys need only to be pre-registered through domestic authorized agencies. Registration of chemicals contained in products can be very cheap. For chemical product exporters, two procedures are required for pre-registration and formal registration.

Chemical product exporters need to register chemical substances contained in their chemical products one by one. If they are deemed to be permitted by the EU, they will only need to pay the basic registration fee. In the case of new chemical substances, the test cost may be as high as 450,000 Euros. If chemical components that are found to be inadmissible during the test are used, the product cannot be registered and it is necessary to look for alternative chemicals.

At present, the EU has not announced the list of substances of very high concern that it is not allowed to use. It is reported that the European Chemicals Agency will issue a list of substances of very high concern in 2009, about 1900 species.

According to EU regulations, the pre-registration stage of the enterprise will be as of November 30, 2008. Enterprises whose annual export volume of chemicals exceeds 1,000 tons should complete registration within 3 years. Production volumes ranging from 100 tons to 1,000 tons should be registered within 6 years. Products that fail to complete registration on schedule cannot be sold on the EU market.

According to EU estimates, REACH regulations will increase the cost of export products to the EU by 5%-10%. At present, because our country's laboratories have not yet obtained the international GLP standard certification, export companies need to conduct related experiments abroad, which greatly increases the cost of testing.

However, according to sources from the French International Inspection Agency, China is preparing more than 60 such laboratories.
At present, Fujian Province cooperates with the International Bureau of Inspection in France and selects two Fujian sports shoes and plastic shoe manufacturers as a model to carry out preparations for responding to the REACH regulations.

Pan Yanglu introduced that footwear manufacturers as finished products enterprises, deal with REACH regulations mainly to collect and sort out corporate data and complete pre-registration. However, due to the non-standard domestic market, production companies cannot successfully obtain raw material contained in the raw materials contained in the raw materials. For example, there may be more than 1,000 raw materials that may be involved in a sports shoe manufacturing facility. Many small shoe companies have scattered supply channels, and some raw material suppliers do not have the technical ability to provide information on the chemical substances they use.

Collecting this information in an unregulated market requires a lot of manpower and effort. Many companies are unable to do it. Some small businesses simply choose to give up.

Sun Huaibin, director of the Center for Economic Research of China Textile Industry Association, believes that although the REACH regulation treats both EU and foreign companies equally, it is very difficult for developing country companies to meet such high technical requirements in the short term. The textile industry does not rule out finding dyes in Europe. Other raw materials are possible.

Minmetals Chamber of Commerce sources revealed that while Chinese enterprises are struggling to respond to the REACH regulations, they have come forward from the US Chemical Distributors Association and the U.S. Congress to negotiate with the EU. After negotiations failed, they submitted written protests and applications to the WTO. The entire statute is considered to be a disguised trade barrier.

At present, China is waiting to see the controversy between the United States and the EU.

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