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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ECHA Wants to Restrict Flame Retardants in Childcare Items and Upholstered Home Furniture

The ECHA is recommending that the EU Commission strictly limit the use of flame retardants in polyurethane foams. According to the agency, the organophosphates TCEP, TCPP, and TDCP significantly increases the risk of cancer. That’s the conclusion of a screening report that the ECHA has posted on its Web site.

The chemicals are added to foams that are then used in the manufacture of baby mattresses, car seats for children, baby slings, and upholstered home furniture. The use of the materials in baby mattresses is particularly risky because of the large surface area and the relatively lengthy contact, which makes it easy for them to enter the body.

TCEP has been banned for quite some time, but it is still present in the products as a contaminant. Because TCPP and TDCP has similar properties, the ECHA included both in its study. Because TCPP and TDCP have not yet been included in the candidate list, the ECHA needed approval from the EU Commission to create a restriction dossier according to Annex XV of REACH.

In a conversation with Chemical Watch, the president of the European Furniture Industries Confederation (EFIC), Markus Wiesner, criticized the restriction proposal as too narrow. Instead of focusing only on upholstered furniture intended for home use, it should be expanded to cover all type of furniture and textiles, he said. Some time ago, the EFIC began a case against the special rules for flame retardants in the UK and Ireland, but no final decision has yet been made. He feels that these special regulations would hinder a
restriction across the whole of the EU and thereby torpedo consumer protection.

The EFIC and nine other industry associations in Europe have founded the Alliance for Flame Retardant-Free Furniture (FRFF). The EFIC itself represents about 130,000 small and midsize companies in 15 EU countries.

Remember that only safe products can guarantee long-term customer relationships. Please contact us at reach@kft.de with any questions.

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Automobile Industry Wants to Introduce Regulatory Radar

According to a report from Chemical Watch, this summer the European Automobile Manufacturers Association (ACEA) wants to implement a regulatory radar, a monitoring system for regulatory activities. The ACEA itself has also spoken of a Global Regulatory Monitoring System of Substances (GRMS).

The system is to collect information on planned laws and initiatives related to chemicals used in the automobile industry. The information would then be made available to automobile manufacturers and their suppliers. Such a system is an important aid for companies when they seek to remove chemicals that cause environmental and health hazards and develop substitutes in good time.

We always keep an eye on all important regulatory activities and are happy to answer any questions. Please contact us at reach@kft.de.

 

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Cosmetics: Substances That Trigger Most Allergies

The National Institute for Public Health and Environment (Rijksinstituut voor Volksgezondheid en Milieu: RIVM) in the Netherlands has published its current RIVM Report on the frequency of allergic reactions to cosmetics. According to the report, isothiazolinone (21% of cases) and fragrances (46% of cases) cause most of these allergies. The triggers are products for skin and hair care that lead to classic symptoms like erythema, scaling, and itchiness on the face and hands.

As early as 2009, the Institute set up a control system, Consumer Exposure Skin Effects and Surveillance (CESES), a database that stores information on allergic reactions related to cosmetics. Dermatologists register these cases routinely and have a good overview of the frequency and causes of such allergies. Since the inception of CESES, the number of registered cases has grown continuously. Between October of 2015 and October of 2017, some 90 cases were documented.

Last year, members of the EU Standing Committee on Cosmetic Products further limited the use of the preservative methylisothiazolinone (MIT): See EU Bans Allergenic Fragrances. The authors assume that the number of cases related to methylisothiazolinone will decrease in 2018.

Since August 2017, CESES has also collected data on skin injuries that result from tattoos.

Make sure you take care of the legal compliance of your products as early as possible. If you have any questions, please contact us at cosmetic@kft.de.

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German Chemical Industry Association Warns of a Hard Brexit

On the anniversary of the British application for Brexit on March 28, Utz Tillmann, chief executive of the German Chemical Industry Association (VCI), warned about the consequences of a hard Brexit for the
German chemical and pharmaceutical industries. Although the parties have reached agreement on the transition phase, a hard Brexit continues to be an option until a treaty is signed. The VCI has issued a
press release (only in German) on the topic.

If a hard Brexit scenario comes to pass, supply chains will be interrupted. At the same time, German
companies would face annual tariffs of about €200 million. Great Britain is one of Germany’s most important trading partners. In 2016, the industry sold products valued at almost €12 billion to Great Britain, some 6.7% of German chemical exports. Germany companies also imported products valued at € 6.4 billion, some 5.2% of German chemical imports. The VCI has published current statistics (in German only) on the trading
relationships.

In a position paper (only in German) The VCI called for:

  • Waiving tariffs on chemicals and pharmaceuticals, regardless of a free trade zone, a customs union, or some other special relationship that is yet to be defined.
  • Clear regulations, especially for technical barriers to trade (TBT), sanitary and phytosanitary measures (SPS), non-tariff trade barriers, the protection of intellectual property, and dispute resolution.
  • An approach that ensures that trade controls between the EU and UK are as rapid as possible.
  • Clear regulations on how EU property rights can be transferred into national UK law.
  • Participation of Great Britain in a unified EU patent court system.

In general, says the VCI, strict environmental standards should continue to be harmonized in the EU27 and the UK. In this context, continued UK membership in the European Chemicals Agency (ECHA) would be
desirable. Tillmann sees a positive sign in a speech given on March 2 by Prime Minister May in which she showed openness to continued membership.

The ECHA Web site shows the effects of Brexit throughout the EU.

If you have any questions on this topic, please contact us at reach@kft.de.

<Twitter>

Der #Verband der Chemischen Industrie warnt vor hartem #Brexit und befürchtet die Unterbrechung von #Lieferketten und #Zollzahlungen in Höhe von bis zu 200 Millionen Euro.

 

German #ChemicalIndustryAssociation (#VCI) warns of a hard #Brexit and fears the breakdown of
#SupplyChains and payment of #Tariffs of up to €220 million.

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REACH 2018: ECHA Offers and Recommendations

Effective immediately, the ECHA will provide REACH-IT around the clock to all companies that want to register substances. The ECHA will also hold a Webinar on April 19 (11:00 a.m.–12:30 p.m.) that allows prospective registrants to pose questions and obtain comprehensive information on registration. The questions to be covered include:

  • What happens if the data on test results in submitted late?
  • What do I do when vendors do not register?
  • What should I do when conflicts arise during a joint registration?

The Webinar will also treat questions related to lead registrants and the Substance Information Exchange Forum (SIEF).

In a conversation with ChemicalWatch, the ECHA indicated the importance of submitting registration documents before the deadline on May 31 – even if some data in missing. Any incomplete data can be submitted later.

At the end of March, some two months before the end of the registration period, the ECHA had received a total of 18,037 registration dossiers for 7,452 substances. Some 4,975 of the submissions were for new substances. A total of 3,236 companies submitted dossiers, and 544 of them did so for the first time in 2018. The ECHA provides up-to-date registration statistics on its Web site.

Because they do not yet have data on test results, companies have so far requested extensions of the deadline about 160 times We reported on this ECHA offer in our blog entry REACH 2018: New Deadline for Registrants. Because of heavy demand, the ECHA wants to keep the Web site of the Directors Contact Group (DCG) up to date.

We are pleased to assist you with any questions about REACH at reach@kft.de.

 

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Australia: Agency Laments Violations by Cosmetics Firms

On its Web site, the Australian National Industrial Chemicals Notification and Assessment Scheme (NICNAS) complains that many cosmetics firms violate current law and must therefore count on significant fines.

The background: Companies that want to import new substances – like the ingredients of cosmetics – to Australia must register the chemicals with the NICNAS according to the Australian Industrial Chemicals – Notification and Assessment – Act 1989). Nevertheless, companies are exempt from the notification requirement in certain cases. For example, the requirement does not apply if the concentration of the chemical in cosmetics products is less than 1% by weight. However, companies must have NICNAS approve the exemption and provide information on the substance to be imported. For example, companies must provide information on the health safety of the substance along with other data (like aquatic toxicity). But the failure of companies to deliver this information is precisely what has angered the leaders of NICNAS.

Three-quarters of all the substances covered by exemptions are cosmetics. According to the most recent NICNAS report, an exemption was claimed for 3,249 substances between September 2016 and August 2017, and companies stated that concentrations of all were under the 1% rule. Additional grounds for exemptions are defined in Sections 21(4) and 21(6) of the Industrial Chemicals – Notification and Assessment – Act 1989. More information on this you will find in the NICNAS report mentioned above.

The chemicals law is currently being revised, and the process is being postponed to 2019.

Do you operate in the Australian market? Please contact us at reach@kft.de.

 

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Japan Plans a Notification System for Mixtures

The Japanese Ministry of Economy, Trade, and Industry (METI) is planning to develop a notification system for substances of unknown or variable composition, complex reaction products, or biological materials (UVCB). Japan wants the system to improve risk assessment for and monitoring of such types of mixtures. The changes are being added to the Japanese Chemical Substances Control Law (CSCL). Details on the notification system are still being discussed, but the system should be complete in April of next year.

The plan calls for collecting the formulas and components of UVCB to enable better assessment of their hazards. Moreover, a screening test of chemical substances (priority assessment of chemical substances: PACs) is to identify chemicals that should have a higher priority in the assessment because of their hazardous characteristics. According to the CSCL, manufacturers and importers of PACs must submit information on the chemicals and explain their use. Special regulations cover the manufacture and use of PACs that involve special risks.

The following are sample items in the list of UVCB:

  • Substances with carbon chains of varying length
  • Substances extracted from oil or oil-like sources
  • Extracts from biologic materials (natural fragrances, natural oils, and so on)
  • Complex biological macromaterials (enzymes, proteins, and hormones)
  • Concentrates or melts (like residues of smelting processes and slag)

This document offers a good overview of UVCBs.

In Germany, all registrants are responsible for identifying their substance in the appropriate manner.

For more details, see chapter 4.1 of the guidelines (German only) for the identification and classification of substances according to REACH and CLP.

Please contact us with any questions at: reach@kft.de.

 

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