Vietnam: New Chemicals Law and Threshold Values for Formalde-hyde and Azo Colorants

Vietnam has approved a new chemicals law. Decree No. 113/2017/ND-CP (only in Vietnamese) took effect on November 25, replacing the previous law, No. 108/2008/ND-CP. The Vietnam Law & Legal Forum issued a notification of the new law at the end of October.

At the International Chemical Management Conference at the beginning of November, a government spokesperson gave an overview of the new law. It includes new requirements for the bottling and packaging of chemicals. Furthermore, it defines clear criteria for each list of chemicals (Annex I to Annex V) related to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The list of toxic chemicals has been abolished, as is the requirement to register the use of chemicals. You can find detailed information on the new law here.

In addition, the Vietnamese Ministry for Industry and Trade (MoIT) and the Vietnamese General Department of Customs have created an electronic declaration system for imported chemicals. With the new system,

Vietnam seeks to simplify, accelerate, and, above all, avoid all errors in import and approval processes. In the future, companies must use the electronic declaration window defined in Article 27 of Decree 113/2017/ND-CP to declare their chemicals. Companies can register at the government’s Web site (only in Vietnamese).

The MoIT has also set threshold values for formaldehyde and azo colorants in textiles. The Ministry has published a notification (only in Vietnamese) on the law. The new regulations take effect in May 2019, and define the following thresholds:

  • 30mg/kg in textile products for children under three;
  • 75mg/kg in textile products in direct contact with the skin;
  • and 300mg/kg in textile products with no direct skin contact.

The law also sets the threshold for 22 aromatic amines at 30 mg/kg. Amines are a component of azo colorants.

The new law has been published as Number 21/2017/TT-BCT: The national technical regulation on the content of formaldehyde and certain aromatic amines derived from azo colourants in textile products.

If you import products into or export products from Vietnam, we are happy to answer any of your questions at

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Turkey: Training for KKDIK Experts Starts

KKDIK, the Turkish REACH law, takes effect on December 23, although not enough experts are available yet to handle chemical assessments. Candidates need to overcome some rather significant obstacles to attain the required expertise, which is defined in Annex 18 of the KKDIK Regulation.

According to the Annex, only those who have worked for ten years at the ministry as experts in chemicals management or who have a certificate that has been recognized by an official agency (Turkish Accreditation Institution: TÜRKAK) are allowed to train trainers.

Classes continue at the start of 2018. Successful completion of the class requires correct answers to 70% of the questions. Part 5 of the Annex defines the topics that are to be examined and how they are weighted. Our partner, CRAD, has been able to engage Haydar Hazer of the Turkish Environmental Ministry as a trainer and offers eight one-day courses for up to 20 persons.

We have been successfully supporting companies that operate in the Turkish market for several years. Please contact us with any questions:

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REACH 2018: Far Fewer Registrations Than Expected

Almost six months before the registration deadline for substances in quantity bands greater than one ton in May 2018, the number of registration dossiers submitted to the ECHA continues to rise. But only about 12,500 registrations have been submitted so far. Of that number, approximately 6,000 are part of that band, and only 3,600 of the 6,000 compounds are new registered substances. However, the ECHA originally expected about 25,000 registrations instead of the 6,000 it has received. The numbers fell far short of estimates, admits Christel Musset, director of registration, in the November issue of the ECHA Newsletter. But the numbers are still not a worry for the industry association.

Some 95% of small and midsize companies are aware of the urgency of registration. A lack of awareness is not the problem, emphasized outgoing ECHA director Geert Dancet in an interview with Chemical Watch in November. It’s much more a matter of the high costs that cause many firms to delay. Dancet’s statement aligns with the results of a study sponsored by the ECHA and undertaken by a British consultancy, Risk & Policy Analysts (RPA). See also our recent article, REACH 2018: ECHA Seeks Financial Relief for Smaller Companies. Along with the authors of the study, Dancet urges companies to provide the required funds and expressly warns of market shortages. Such a problem would arise if companies abandon the market or throttle back production.

That’s why in its meeting on November 27, the Directors‘ Contact Group (DCG) appealed to the companies involved to communicate clearly to their customers their registration intentions and the applications that the registrations cover. The members of the DCG also agreed to publish information on possible financial support from the EU. See the DCG press release of the ECHA for further information and links.

If your company is affected by these issues, please contact us at any time at

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California Places Perfluorinated Compounds on the Prop 65 List

The California Office of Environmental Health Hazard Assessment (OEHHA) considers
perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) as developmental toxins and has placed both compounds on the Prop 65 list. The Office based its decision on a finding of the EPA, which classifies both substances as toxic to reproduction. However, the EPA has not limited use of the compounds. Both agencies argue that ultimately, proper use of the substances does not pose any danger to human health or the environment because exposure is limited. Accordingly, the American Chemistry Council (ACC) has criticized the OEHHA for moving too quickly.

Consumer protection is the goal of Prop 65. The law lists more than 800 chemicals as carcinogenic and toxic to reproduction. The list is updated and published once a year. Companies that want to sell consumer goods, like textiles, utensils, do-it-yourself articles, toys, items for young people, and electronic and electrical products, must ensure that their products do not pose any significant danger to health. But if they do pose any danger, they must be labeled with clear warnings.

Only in June 2017 did the EU decide on restriction procedures for PFOA and precursor substances; as of July 4, 2020, PFOA may not be manufactured or sold. The threshold for PFOA is set at 25 ppb and at 1,000 ppb for PFOA precursor compounds. Exceptions apply only to protective work clothing and fire extinguisher foams. PFOA is also a candidate for inclusion in the list of the Stockholm Convention on persistent organic pollutants. PFOS has been included in Annex B of restricted substances since May 2009.

Questions about PFOA and other restricted chemicals? We are here for you. Please contact us at

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ECHA: Many SVHC Not Covered by Legal Regulation

The ECHA has found seven substances on the Substitute It Now (SIN) List by ChemSec that are neither covered by legal regulations nor inspected by government agencies, even though they might be hazardous to health and the environment.

The substances include:

  • CAS Number EC-401-500-5: (methylenebis(4,1-phenylenazo(1-(3-(dimethylamino)propyl) -1,2-dihydro-6- hydroxy-4-methyl-2-oxopyridine-5,3-diyl))) -1,1′-dipyridinium dichloride dihydrochloride
  • CAS Number EC-432-750-3: o-hexyl-N-ethoxy carbonylthiocarbamate
  • CAS Number 68391-11-7: pyridine, alkyl derivatives
  • CAS Number 68411-07-4: copper lead resorcylate salicylate complex
  • CAS Number 93763-87-2: slags, lead-zinc smelting
  • CAS Number 99328-50-4: nitric acid, barium salt, reaction products with ammonia, chromic acid (H2CrO4) diammonium salt and copper(2+) dinitrate, calcined
  • CAS Number 78-87-5: 1,2-dichloropropane (propylene dichloride)

The ECHA wants to consider appropriate measures together with individual countries.

The SIN List is a database create by ChemSec, a Swedish environmental organization. It currently includes entries for 912 substances that have environmental and health-related characteristics. It was last updated in October 2017.

In mid-November, the ECHA published an analysis of the SIN List that indicated that the EU already regulates 270 of the more than 900 chemicals on the list. About 280 substances are being examined right now, including bisphenol F, which could function as a substitute for bisphenol A because of its similar structure. The background of the analysis is the ambitious SVHC road map of the ECHA, which seeks to identify all SVHC by 2020. The REACH help desk (German only) describes the realization of the road map at the EU level in detail along with the activities of the ECHA.

Select your substitutes for SVHC in good time. If you have questions about the restrictions created by REACH or classification according to the CLP Regulation, contact us at

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Denmark Cancels Tax on PVC and Products Containing Phthalates

At the start of 2019, the Danish government will no longer collect taxes for products that contain PVC and phthalates – binders, gloves, aprons, rainwear, and other protective clothing. Officials state that the tax, which was enacted in 2000, has fulfilled its two main purposes. First, manufacturers were to use substitutes for the chemicals. Second, the tax was to reduce the amount of PVC products deposited or incinerated.

Since the original tax was enacted, many of these critical substances have been classified as toxic to reproduction. Some have been included in the REACH list of substances that require authorization; others have been completely forbidden in specific products, such as toys. Four phthalates, DEHP, BBP, DBP, and DiBP have been included in EU Directive 2011/65/EU on the restriction of hazardous substances (RoHS2), which applies to certain hazardous chemicals in electric and electronic devices.

The end of the tax will save the companies involved about €1.75 million annually. The savings are an express desire of the government, so that the competitiveness of such companies can be strengthened.

An NGO, the Danish Ecological Council criticized the end of the tax as counterproductive. The leader of the organization, Christian Ege, fears that the substances that have been successfully restricted in the past will become competitive again.

To avoid exactly that outcome, the government created the Danish Chemicals Forum, a group of experts consisting of representatives of government, industry, and NGOs. The council has started a campaign aimed at products imported into the EU. As part of the campaign, for example, the Danish Environmental Protection Agency will inspect products more closely for legal compliance, with a particularly close eye on the four phthalates BBP, DEHP, DBP, and DIBP.

Do you have any questions about problems with phthalates or other restricted substances? We are always ready to help at

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ECHA Finds Forbidden Substances in Toys

A project of the ECHA Enforcement Forum for REACH has inspected 5,600 products, among them almost 500 toys, from 29 countries. The result? Every fifth toy contains forbidden substances like DEHP, DBP, and BBP. Some 12% of the jewelry inspected contained cadmium, and 13% of the leather goods contained chromium VI. In their analysis, the scientists primarily looked for substances like phthalates and heavy metals, such as cadmium, that are listed in REACH Annex XVII.

The leader of the study, Marilla Anttila, was concerned that the origin of four out of ten articles is unknown. She appealed to the national agencies that are responsible to keep a particularly close eye on jewelry. She made her comments at the Chemical Watch European Enforcement Summit held in Brussels in mid-November. The ECHA will publish a comprehensive closing report on the project at the end of the year.

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