Correctly understand the Chinese version of “REACH” regulations

Recently, the solicitation for opinions on the national standard “Restriction Requirements for Chemical Hazards of Consumer Products” has ended, marking that following the official implementation of the Chinese version of RoHS 2.0 on July 1, 2016, the national version of “REACH” will be released soon.

The standard is under the jurisdiction of the National Consumer Product Safety Standardization Technical Committee (SAC/TC 508) and jointly drafted by the China Institute of Standardization, the China Academy of Inspection and Quarantine and other units.

The standard is based on the European Union’s “REACH Regulation ((EC) NO 1907/2006)” and stipulates the regulation of 103 heavy metals, alkanes, haloalkanes, alkenes, benzene, polycyclic aromatic hydrocarbons, phenols, aldehydes, ethers, alcohols, and esters. And the restriction requirements for salts, amines, dyes and other unclassifiable chemical substances, like EU REACH, are basic safety requirements for the hazards of chemical substances.

So as the national version of REACH regulations, what are the differences in content and implementation between it and EU standards?

01 The “Restriction Requirements for Chemical Hazards of Consumer Products” does not have the requirements for registration, evaluation, authorization, notification, etc. of chemical substances in the EU REACH, but only stipulates the requirements for the prohibited and restricted use of chemical substances.

02 EU REACH controls all chemicals entering the EU market, while the “Consumer Products Chemical Hazard Limitation Requirements” only targets hazardous chemical substances related to consumer products.

The “Restriction Requirements for Chemical Hazards of Consumer Products” is based on the definition of consumer products in the national standard of “Classification of Consumer Products”, eliminates chemical substances for industrial use in the EU REACH, selects harmful chemical substances related to consumer products, and based on my country’s existing various consumer product standards and technologies Requirements, adding hazardous chemicals not included in the “REACH Regulation”, such as 2-mercaptobenzothiazole (MBT) (CAS No. 149-30-4) and antioxidants (2,6-di-tert-butyl-p-cresol and 2,2′-methylene-bis(4-methyl-6-tert-butylphenol)), etc., a total of 103 substances.

According to the definition, consumer goods refer to products designed and produced for but not limited to personal use, including product components, parts, accessories, packaging and instructions for use, excluding food, drugs, cosmetics, tobacco, special equipment, aircraft, ships, Military products and other products subject to special government supervision.

03 The EU REACH regulations do not overlap with other EU product regulations, and the “Consumer Product Chemical Hazard Limitation Requirements” is more inclined to summarize and integrate the substance restriction requirements in existing standards.

For the same restricted substance, if there are clear requirements in EU laws such as the EU Toy Directive, RoHS Directive, POP regulations, food contact regulations, etc., the REACH regulations will not repeat the requirements;

In the “Restriction Requirements for Chemical Hazards of Consumer Products”, for hazardous chemical substances that already have restricted requirements in consumer products in China, the restriction requirements are consistent with existing consumer product-related standards;

For hazardous chemicals that do not have restriction requirements in domestic consumer products, please refer to the EU “REACH Regulation ((EC) NO 1907/2006)” “EN71-9 General Requirements for Organic Compounds in Toys” and “EN71-12: 2013 Toy Safety – Part 12N -Nitrosamines and N-nitroso compounds” and the restriction requirements of foreign standards such as “Ecological Textile Standard Oeko-tex100-2017”.

04The ranking of restricted substances in Annex XVII of the EU REACH regulations is mainly generated naturally based on the proposal and adoption order of restriction requirements, while the “Consumer Product Chemical Hazard Restriction Requirements” is generally based on heavy metals, alkanes, haloalkanes, alkenes, benzene, and polycyclic aromatic hydrocarbons. Chemical substances such as phenols, aldehydes, ethers, alcohols, esters and salts, amines, dyes and other unclassifiable chemicals are sorted from simple to complex.

05 The “Restriction Requirements for Chemical Hazards of Consumer Products” is open to new hazardous chemical substances and consumer products.

The hazardous chemical substance restriction requirements described in this standard are low safety requirements that enterprises should follow. If there is an emerging new product that does not have corresponding product standards, if the user group, usage method and usage environment of the new product are similar to an existing product category, the hazardous chemical substance restriction requirements can refer to the relevant restrictions of the existing product. Require.

Source: China Fiber Inspection Micro Platform