KFT Goes to Hollywood

People say that a picture says a thousand words. How much more do movies say? But how can a film cover the complex topic of regulatory chemical compliance? And how could anyone develop a meaningful plot based on it?

Regulatory chemical compliance appeals to our desire for safety and security, so it also deals with trust. Customers and users want trustworthiness and transparency. They want to be sure that a product actually contains what the label indicates and that the label indicates what a product actually contains– and they want to do both seamlessly. Those who take that to heart will have fans on their side. In short: Brands that want to be seen as likeable and reputable should at least do what the law requires.

But enough with the words: Let the pictures speak!

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Brexit: British Chemicals Industry Opposes Separate British Compliance Regulations

Seven of ten companies surveyed fear that separate British compliance regulations will have negative effects on their trade relations with the European Union. That’s the finding of a survey of the British Alliance of Chemical Associations (ACA), the results of which were provided only to the news platform ChemicalWatch.

The ACA is a group of 11 trade bodies and represents the interests of more than 1,000 predominately small and midsize enterprises in the chemicals and affiliated industries. Two-thirds of the firms are headquartered in Great Britain.

More than 100 firms participated in the survey. Three-quarters of them see Brexit as a risk and also consider REACH and CLP as important to their operational business. More than half of the companies regard a free-trade agreement with the EU as less helpful, and every fifth company would even consider moving their business out of Great Britain.

For most of the small and midsize companies, high levels of investment in regulatory services are a significant burden. They indicate that they invest about 15% of their profit in compliance measures. Some 62% of respondents believe that separate British regulations would increase that figure.

A survey of managers conducted by the British Coatings Federation (BCF) found similar statements. The BCF has summarized the results of the survey in a closing report. In this survey as well, three-fourths of companies spoke against separate British regulations. And the attitudes toward REACH are even clearer. Nine of ten companies regard REACH as having the highest relevance possible. And 82% of the companies regard CLP the same way.

If you need support with issues related to REACH or Brexit, please contact us at reach@kft.de.

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China Seeks to Ban Hazardous Substances from Consumer Products

At the end of March, the National Consumer Product Safety Standardisation Technical Commission in China announced (in Chinese only), that it wants to ban certain chemical substances from consumer products in the future. The substances involved include:

  • Heavy metals such as cadmium, chromium (VI), lead, mercury and nickel
  • Organic chemicals such as benzene, BPA, dyes, polycyclic aromatic hydrocarbons (PAHs), phthalates, polybrominated biphenyls (PBBs), polybrominated diphenyl ethers (PBDEs) and short chain chlorinated paraffins (SCCPs)
  • Organometallic compounds such as organotins and salts

According to the international inspection company SGS, the Chinese plans align with various national and international standards, including:

The list also includes three substances that REACH does not limit: benzothiazole-2-thiol (MBT), antioxidants (2, 2) 6-di-tert-butyl-p-cresol, and 2,2′-methylene-bis (4-methyl-6-tert-butylphenol).

We know the market and the regulations on chemical compliance in Asia. Please contact us at sds@kft.de.

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Turkish REACH to Arrive in Summer

“We expect publication of the Turkish REACH regulation in summer,” says Melih Babayigit, general director of CRAD, a Turkish chemical compliance service provider, at the KFT Info Day on May 11 in Darmstadt. The new law (abbreviated as KKDIK in Turkish) has already been signed by the minister of the environment and was sent to the office of the Turkish prime minister a few weeks ago. As soon as the prime minister gives the green light, the law will be published in the official journal and take effect six months later. KKDIK will then apply in full and replace three previous laws that had previously been in effect:

  • Chemical Inventory and Control Regulation (CICR 27092)
  • Regulation on Restrictions for the Manufacture, Marketing and Use of Certain Dangerous Substances & Preparations (27092)
  • SDS Regulation (29204)


The new law consists of 12 titles, 66 articles, and 17 annexes – for a total of 405 pages. “I get a lot of questions about an English translation of the correct version, but that would not make a lot of sense. About 95% of the new law is identical to REACH. In other words, the entire regulation was translated almost one-to-one into Turkish, says Babayigit. But KKDID does not include Articles X–XIII of REACH because those articles relate to the ECHA and the classification and labeling of substances. Those considerations are irrelevant for Turkey, where the ECHA plays no role and the 28848 SEA Regulation has played an analogous role since December 11, 2013.

It should be noted that all safety data sheets must be created by a certified employee in Turkish. Chemical names must also be given in Turkish, especially for substances listed in Annex VI of the SEA Regulation.

Data entry and transmission in Turkey occurs over the KKS system, which is similar to the system used for REACH. However, KKS features less functionality – it is missing a bulk registration utility, for example.

Any companies affected by the law must consider the deadlines it defines. If it appears, as expected, in summer, manufacturers or importers who want to market a substance in a quantity greater than one ton before December 31, 2020 must have it preregistered between January 2018 and December 31, 2020. After December 31, 2023, substances must be registered before they can be marketed. You can also find information on the deadlines in an article by Melih Babyigit in the current issue of Turkchem Magazine.

You can also download the following presentations given by Melih Babayigit:

Chemical Control Regulation in Turkey – Notification & Registration Schemes

Product Registration & Notification Regulations – Biocidal Products and Detergents

We have worked very successfully with our Turkish partner CRAD for several years. If you operate in the Turkish market, please contact us at sds@kft.de.

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Consumer Protection: New Apps for Data on Hazardous Materials in Everyday Products

The German Federal Environmental Agency (Umweltbundesamt: UBA) and the German Federation for the Environment and Nature Conservation (Bund für Umwelt und Naturschutz Deutschland e.V.: BUND) are offering consumers new apps. The software can be used to contact manufacturers for information on the presence of substances of very high concern (SVHC) in everyday products.

With the app from the UBA, Scan4Chem, users can scan the bar code of a product and automatically transmit a query to the supplier, who must fulfill the request within 45 days. A direct query about the contents, however, is enabled only if the information is stored in the related database.

That is already the case with the BUND app, ToxFox, although it is primarily geared to cosmetic products. According to BUND, ingredient information on more than 80,000 personal care products is available. The app is also optimized for children’s toys, and other product groups are to follow soon. But consumers can submit queries even if the system does not yet contain information about questionable contents. In such cases, BUND redirects the query to the manufacturer. And BUND also supplies handy user guide (in German only) for the app.

According to Article 33 Section 2 of REACH, manufacturers and importers are obligated to provide information as soon as the concentration of a critical substances in a product crosses the threshold of 0.1% by mass. The products and objects covered include household goods, textile, shoes, sporting equipment, furniture, home-improvement products, electric and electronic devices, vehicles, and packaging.

SVHC include substances that:

  • Are carcinogenic, mutagenic, and toxic to reproduction
  • Are poisonous and persistent and that concentrate in organisms
  • Have hormonal affects

These substances are new registered at ECHA 173 SVHC.

We are familiar with the laws surrounding the use of SVHC. Please contact us at reach@kft.de.

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Vietnam Updates Chemicals Inventory List

Vietnam’ s Ministry of Industry and Trade (MOIT) has published an updated version of the National Chemicals Inventory and a parallel Announcement (in Vietnamese only). The list now contains entries for 4,927 substances. That number includes about 1,500 more substances than the first version, which was published at the end of last year.

Companies can comment on the list and suggest additions by contacting the ministry. ChemicalWatch has indicated that substances not on the list will be considered new and require registration.

Vietnam’s chemicals law dates from 2007. Its provisions cover how to work with chemicals and the obligations that companies have when dealing with chemicals.

If you operate on the Vietnamese market, we would be pleased to support you. Contact us at reach@kft.de.

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RAPEX: More Recalls for Cosmetics and Personal Care Products

The number of recalls for cosmetics, personal care, and household products (CPCH) grew by two-thirds in 2016, in comparison to 2015. That’s the finding published in the RAPEX Recall Report 2016 of SGS, the international inspection company. The company also issued a press release on its findings, which states that 79 products were recalled in 2015, and 124 in 2016. The five most-frequently recalled products include:

  1. Bathing products, shower gels, and skin cleansers (18)
  2. Incense sticks and other fragrances (13)
  3. Skin-lightening products and cremes (13)
  4. Tattooing inks (10)
  5. Hair colorings (9)

Preservatives (like parabens and phthalates), heavy metals, formaldehyde, polycyclic aromatic hydrocarbons, and hydroquinone are all involved in the recalls. Nine of the products had to be removed from the market because of incorrect labeling, which failed to list all the allergenic ingredients or meet legal requirements for form and content.

The Rapid Exchange of Information System (RAPEX) is an early warning system for consumer protection. For example, it enables rapid, EU-wide information exchange on recalls – whether initiated by a governmental agency or a manufacturer. The EU provides statistical data in its annual report. The current RAPEX Annual Report appeared in March.

The EU collates notifications from the early-warning system weekly. The Web site of the Federal Office for Consumer Protection and Food Safety provides a good overview of the procedures followed in Germany for cosmetics and items for daily use.

Ensure the safety of your products at all times. We can help. Contact us at cosmetic@kft.de.

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CLP: Transition Period for Hazardous Mixtures Expires in June

As of June 1, 2017, hazardous mixtures, such as household cleansers, solvents, or construction chemicals, must be in full compliance with the requirements of the CLP Regulation. That’s the finding of The Federal Institute for Occupational Safety and Health (Bundesanstalt für Arbeitsschutz und Arbeitsmedizin: BAUA – site in German only) announced in a press release. Until June, a transition period covers mixtures that were classified, labeled, packaged, and marketed before June 1, 2015. See our blog entry What’s Noteworthy About CLP.

Businesses are now urged to arrange for rapid sales of mixtures that were labeled according to the old standards. The new labels can be recognized by the diamond-shaped CLP pictograms with a black symbol and a red frame. The BAUA recommends that customers reject products with the obsolete labeling after June 1, 2017.

The end of the transition period does not apply to commercial and private users who purchased mixtures with the old labeling, but who cannot exhaust all their supplies before June. Clearly, these mixtures can still be used after the cut-off date. The labels do not need to change for mixtures used internally.

Please take note of a CLP Brochure (in German only) issued by the German Chemical Industry Association. If you have any additional questions, please contact us at kft@clp-info.de.

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