The Enforcement Forum of ECHA agreed that the next REACH enforcement project will investigate how companies fulfil the registration, authorisation and restriction obligations for products and chemicals they import from outside the EU. The project will be done in 2023-2025 and will require close cooperation between REACH enforcement and national customs authorities in the Member States.
In ECHA November meeting, the Enforcement Forum, responsible for harmonising the enforcement of EU chemicals legislation, agreed to focus its next project on the control of imports of substances, mixtures and articles.
Previous years of enforcement content
Enforcement Time | Enforcement Item No. | Enforcement Content |
2009-2011 | REF-1 | Focus on checking substance manufacturers and importers for REACH registration compliance and SDS compliance. |
2011-2012 | REF-2 | Focus on checking whether downstream users comply with the basic requirements set out in REACH and CLP regulations, including SDS for mixtures or configurations (paints, coatings). |
2013-2014 | REF-3 | Focus on checking whether manufacturers, importers and ORs comply with REACH obligations, especially the registration obligations of Article 5 and 6 of the REACH regulation. |
2016-2017 | REF-4 | Focus on checking whether the 14 substances that may exist in consumer products meet the relevant restrictions stipulated in Annex XVII of the REACH Regulation. These consumer products include but are not limited to professional products such as textiles, players, jewelry, glues and brazing fillers. |
2017-2018 | REF-5 | The enforcement action focused on reviewing SDS quality; reviewing whether the extended safety data sheets (eSDS) produced by chemical manufacturers containing downstream importer uses matched the chemical safety reports (CSRs) |
2018-2019 | REF-6 | Focus on checking the classification and labeling of the mixture, including the classification labeling information in the SDS. |
2019-2020 | REF-7 | Focus on checking compliance with REACH registration of importers and producers in the EU. |
2020-2021 | REF-8 | The enforcement focuses on the compliance of substances, mixtures, and articles sold online with REACH, CLP regulations, and BPR regulations. The inspection focused on compliance with the REACH restriction requirements for cadmium, nickel, lead, CMR substances, phthalates, polycyclic aromatic hydrocarbons, asbestos, and whether the chemicals are labeled with the required safety information. |
2021-2022 | REF-9 | The main check is on the compliance of downstream users with the authorization requirements in Annex XIV of REACH. Most controls are for downstream users, focusing on authorization requirements for chromium trioxide and chromates. |
This subject was triggered by high levels of non-compliance in imported goods detected in previous Forum projects, including a recent pilot project. The pilot found that 23 % of inspected products were non-compliant with requirements set by EU law and further controls are necessary.
Control of imports at the point of entry is the most effective means of checking that non-compliant substances, mixtures and articles do not enter the European market. The project will also work on further developing and strengthening existing cooperation between REACH inspectors and customs. By strengthening the control of imports, the project will also contribute to the goals of the EU’s Chemicals Strategy for Sustainability.
The Forum also agreed to publish its future advice on enforceability of new restriction proposals under REACH.
Opportunities for expanding the future role of the Forum, strengthening the control of imports and other areas were on the agenda in an open session where 41 representatives from stakeholder organisations and four candidate countries joined. Among other topics, the open session also addressed the enforceability of REACH restrictions, for example, in textiles or on the use of lead gunshot in wetlands as well as analytical methods relevant for the control of REACH duties.
CIRS Group reminds the trade enterprises to Europe that the response to REACH regulation is not simply REACH registration. Registration is only the first step of chemical substances under regulatory obligations. From the previous years' enforcement forums, the frequency of compliance SDS verification is extremely high. In addition, REACH regulation has gradually moved from simple chemical substance registration number review to the overall compliance monitoring of products, including authorized substances and restricted substances management. As a comprehensive regulatory service and testing integration service provider, CIRS Group can provide you with one-stop regulatory services.
If you need any assistance or have any questions, please get in touch with us via test@cirs-group.com.
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