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On February 24, 2022, the Latin America and the Caribbean Circular Economy Coalition launched a document envisioning a stronger Circular Economy vision for the region. It intends to inspire governm...

On February 24, 2022, the Latin America and the Caribbean Circular Economy Coalition launched a document envisioning a stronger Circular Economy vision for the region. It intends to inspire governments, stakeholders, and initiatives towards a common goal of sustainable economic development based on circularity.

The Circular Economy in Latin America and the Caribbean: a shared vision considers the regional characteristics when proposing transitional activities from linear economy to a circular one. The initiative is spurred on by the growing global drive to pursue long-term economic prosperity.

Just after a year of its launch (February 2021), the Latin America and the Caribbean Circular Economy Coalition has brought together dozens of government officials, representatives from relevant international institutions, businesses, and academia to accelerate the transition to a circular economy and imagine the future of the region based on a circular economy functioning at scale.

The document is believed to facilitate dialogue, engagement, and exchange, resulting in

·       alignment of policies from developing common standards to developing international policies such as trade and in turn enhance development opportunities

·       interoperability of policy and business schemes, for example by aligning on collection and sorting schemes to sharing a classification or taxonomy scheme.

·       help nurture an inclusive and just transition within countries and regions, for example through the exchange of best practice and understanding of investment needs.

The document is available in English, Spanish, and Portuguese.

European Union (EU)  A new Chemicals Strategy for Sustainability was presented by the EU in 2020 as part of the EU Green Deal. This year, there are major implementations that will be...

European Union (EU) 

A new Chemicals Strategy for Sustainability was presented by the EU in 2020 as part of the EU Green Deal. This year, there are major implementations that will be made to achieve this strategy as Europe transitions to a toxic-free environment. Below is a summary of the key updates to expect this year: 

Revision of the REACH regulation 

The EU plans to revise the REACH regulation this year and this will bring significant changes. A workshop held by the Commission in November 2022 deliberated on this topic and two more workshops will be held in March and June this year.  

New hazard classes and criteria for CLP Regulation 

Like the REACH regulation, the commission also plans to present new hazard classes and criteria for CLP Regulation. In October 2021, the commission specifically said it will revise Regulation (EC) No 127/2008 on hazard classification, labelling and packaging of chemical substances and mixtures (CLP regulation).  

New Proposal 

European Commission proposes to strengthen environment protection through criminal laws. In December 2021, the European Commission adopted the proposal of a new EU Directive aimed at reducing environmental crime. This proposal defines new environmental crimes, obliges Member States to take criminal law measures and sets the minimum level for punishment. 

PFAs restriction proposals

The other regulatory updates include new criteria set up for the concept of essential use and the submission of comprehensive PFAs restriction proposal by Denmark, Germany, the Netherlands, Norway, and Sweden. The regulation regarding the concept of essential use will ensure that the most toxic chemicals are only used if they are essential to health and the society. These are the updates you should look forward to in 2022 considering these changes will affect all chemical companies in the supply network from the manufacturers down to the downstream users. 

China

• China’s NMPA announced children cosmetic working plan to come into force January 1, 2022. On the 1st of December 2021, China’s National Medical Products Administration (NMPA) published a special label for cosmetics that are intended for use by children under 12 years old. From 1 May 2022, newly registered children’s cosmetics must attach the logo. If the cosmetic is already registered or filed when the notification is published, companies must update their labels before 1 May 2023.   

• The draft action plan for managing new pollutants might be finalised in 2022. In October 2021, the Ministry of Ecology and Environment (MEE) presented its draft action plan to manage new pollutants. The plan is expected to include priority chemicals’ new regulations, restrictions, and bans.  

• The additional requirements added to the new cosmetics law in 2021 will take effect in 2022. Measures for the Supervision and Administration of Cosmetics production and administrative measures for registering and filing cosmetics took effect from January 1, 2022. Then, the administrative measures on cosmetics labelling will take effect from May 1, 2022.  

Japan 

• Between now and May 24, companies in Japan have to comply with chemical classification, labelling and SDSs standards accordingly with the GHS sixth revised edition.  

Taiwan 

• EPA extends the deadline of the first batch of PECs (106) to 2024 irrespective of their volume  

• Companies are required to submit data for nine items to the authorities, with items eight and nine – hazard and exposure assessments – can be submitted later  

• Annual Reporting requirement for Phase One Registration between April 1 to September 30   

Australia

In Australia, as a manufacturer/importer of chemicals, you are expected to make an annual declaration of the chemicals you manufactured or imported the previous registration year. For this year, the deadline remains 30th November 2022. Also, the deadline for renewal of registration is 31st August 2022. The renewal of registration applies if you as a manufacturer/importer continues to manufacture/import chemicals. 

For annual declaration, the information you need to submit include: 

• the introduction categories for the chemicals you imported/manufactured during the registration year 

• a declaration that all your introductions were authorised under sections 25 to 30 of the Commonwealth's Industrial Chemicals Act 2019. 

And for the renewal of registration, you need to submit: 

• the value of the chemicals you imported/manufactured during the previous financial year 

• if you are a foreign (non-Australian) business, you will need an Australian Registered Body Number (ARBN) 

India

• Chemicals list under mandatory BIS certification has been updated to 52.  

• An update on ICMSR is expected before June 2022 

South Korea 

• The draft grace period issued for existing biocidal substances will end on 31st December 2022.  

• The use of disposable plastic cups in cafes will be banned from April 2022. 

UK REACH 

For 2 years transition period, the deadline for registering substances (listed below) is on 27th of October 2023. Companies are expected to start their dossier preparation now.  

1. >1000 t/a substances 

2. ≥ 1 t/a CMR substances  

3. ≥100 t/a very toxic to aquatic organisms 

4. ≥ 1 t/a active Candidate list subs. as on 31 Dec 2020 

For 4- and 6-years transition period, the registration deadlines are 27th of October 2025 and 2027 respectively.  

Latin America  

Latin America has recently experienced intense developments in the chemical regulatory sector. Below is a short summary of these developments:  

• Chile: GHS classification will be implemented in phases. Implementation of substances for industrial use is on February 9, 2022, and for non-industrial use, implementation is February 9, 2023. Also, for mixtures, implementation is on February 9, 2025, and February 9, 2027, for industrial and non-industrial uses respectively. 

• Argentina: the new draft will be presented to Congress only after the elections (October-November 2021). 

• Brazil: The Law Bill was presented in the Deputies Chamber in December 2019 and was approved by the Environmental Commission in December 2021. It still has to be approved by the other three Commissions. 

• Chile – Implemented: Enacted in February 2021 by Decree 57. It is a mutual implementation of new GHS standards and chemical control policy. 1st notification deadline August 2024. Notification is mandatory every 2 years since then for ≥1 ton/ year. 

• Colombia: Enacted in November 2021 by Decree 1630, it creates the National Chemical Inventory and enforces new chemical control measures for ≥100 kg per year. We are waiting for publication to know the correct deadline. 

• Costa Rica recently joined OECD and as a requirement is starting to enhance the national chemical agenda. 

• Mexico: The first version was published in 2019 and was expected to enter into force in 2021. However, the National Association of the Chemical Industry proposed changes in December 2020. 

• Peru: Public consultation ended in September 2020. No information has been disclosed since then. The draft intends to implement the GHS and a national chemical regulation concomitantly.   

• Uruguay adhered to the GHS standard; however, it did not announce or start drafting its chemical framework. 

GPC is delighted bringing to you our October Newsletter with a summary of toy regulatory updates around the world and other chemical compliance news. 

Toys, both imported and locally manufactured, constitute a significant market for many countries. Over the past decades, many countries have adopted toy safety regulations or reinforced their current regulatory framework. The United States adopted the Consumer Product Safety Improvement Act (CPSIA) in 2008, and the European Union adopted Directive 2009/48/EC on the Safety of Toys in 2009. They were soon followed by the Eurasian Economic Union, which adopted regulation CU TR 008/2011 in 2011. Turkey adopted a regulation based on the EU Directive on Toy Safety in 2016, and India’s Toy Quality Control Order was enacted in early 2020.

In countries where comprehensive toy safety regulations have been adopted, toys are most often subject to a two-tier regulatory framework. First, a legislative act sets out the general obligations placed upon the industry. Public authorities then request an authorised standardisation body to draft detailed safety requirements in the form of standards. For example, the European Union, the United States, and the Eurasian Economic Union all have both a regulation and a set of safety standards.

Regulatory frameworks applicable to toy safety may vary from one jurisdiction to another. However, they tend to share some common features. Such features typically include a requirement to comply with safety provisions in relation to the toys’ physical, mechanical, electrical, radioactive, flammability-related, and, of course, chemical properties. The second part generally include lists of substances that may not be contained in toys, substances that may be contained under certain concentrations, and migration limits. 

Other common features often consist of a requirement for manufacturers to affix warnings, ensure the toys’ traceability, and perform a conformity assessment prior to placing the toys on the market. Conformity assessment may be performed according to various modalities (e.g. self-assessment or third-party assessment) and normally results in the issuance of a declaration of conformity.

• India - BIS Certification for Safety of Toys 
• South Korea restrictions on heavy metals and phthalates in Children's products
• Denmark implements EU Directives 
• The EU Commission published a draft amendment of the Toy Safety Directive laying out specific limit values for aniline 
• The EU Commission published a draft amendment - adding three new entries to the list of prohibited allergenic fragrances 
• The EU Commission published a draft amendment - adding sixty-one new entries to the list of allergenic fragrances 
• Ukrainian updated toy regulation in line with Directive 2009/48/EC of the EU
• Four years since Turkey Adapted Toy Regulation 
• Brazil Sets Deadlines for Compliance on Toy Regulation 

Taiwan’s Environmental Protection Administration (EPA) has amended its chemical control law ‘Toxic Chemical Substances Control Act (TCSCA)’ and renamed it 'Toxic Chemicals a...

Taiwan’s Environmental Protection Administration (EPA) has amended its chemical control law ‘Toxic Chemical Substances Control Act (TCSCA)’ and renamed it 'Toxic Chemicals and Concerned Substances Control Act (TCCSCA).' This regulation came into force on January 1, 2020."

Companies that manufacture or import Existing Chemical Substance in an annual amount of 100 kilograms or more need to apply for Phase One Registration within 6 months from the date of exporting. Furthermore, if the chemical is in a quantity that is above 1 tonne per year or more and falls under the list of 106 Priority Existing Chemicals (PECs) then companies need to do a Standard Registration. 

In the case of Confidential Business Information (CBI), exporters to Taiwan should communicate with their buyers and register via a Third Party Representative (TPR). 

As a TPR, GPC  can communicate in the supply chain on behalf of your company and also assist you with Phase One & Standard Registration. 

If you have any further questions on TCCSCA compliance, please contact our Regulatory Manager Chia-Sui Hsu at jess@tw.gpcregulatory.com

In a private and recent communication from June 2020, the Health and Safety Executive (HSE) has communicated to GPC (Europe) AB that during this transition period, the UK will remain within the EU-REACH regulatory framework and the UK businesses need to continue to comply with EU REACH in their current roles and in their supply chains. The UK authorities have indicated that, the extent to which the provisions in UK REACH will come into effect at the end of the transition period will largely depend on the outcome of the UK-EU trade deal negotiations. Based on the outcome of negotiations, the authorities might need to change some, or all the provisions and any transitional provision will give sufficient time span for the companies to comply.

UK-REACH and the UK-REACH IT system ‘Comply with UK-REACH’ are currently not in operation. Guidance on how to register under UK-REACH is being prepared by the authorities. Details of the supporting services available to potential registrants (including account creation) for UK-REACH will be released in due course.

GPC (Europe) AB is in constant touch with relevant UK-REACH bodies and will keep you updated as and when the situation changes and/or if there are any new advancements.

If you have any questions, you can contact our UK-REACH manager, Priyanka Manapure at priyanka@in.gpcregulatory.com

Last update: 2020-june 

In a recent personal communication with CIS Centre, Russia got notified that, due to the COVID-19 crisis, the Russian Inventory Notification Deadline due on May 1st, 2020 has been extended 3 more months to August 1st, 2020.

Below is the full excerpt of the communication:

The threat of the spread of the new coronavirus infection resulted in the transfer of several entreprises to remote operations. Considering that and the need to provide industry support measures, the Ministry of Industry and Trade of the Russian Federation informs in addition to the letter dated February 17, 2020, No. IM-10702/13 about the extension of the deadlines. This is for the submission of information procedures for the inventory of chemicals (including as part of mixtures) in circulation and those planned for circulation in the territory of the Russian Federation, until August 1, 2020."

With detailed information on the chemical inventory procedure, please familiarize with the methodological recommendations at http://minpromtorg.gov.ru/common/upload/files/docs/Pismo_EVL_s_metod.rek-mi.pdf ) and on the website of the Association “NP KIC CIS” in the section “Preparation for inventory” (URL: https://ciscenter.org/tabstest/faq.php )

If you are exporting to Eurasian Economic Union (EAEU: Russia, ​Belarus, Kazakhstan, Kyrgyzstan, & Armenia) and has not yet notified your chemical(s) in the Russian Inventory then GPC within its Russian Legal entity can act as a Nominated Representative (located in the EAEU) for your company, and can submit your chemical(s) notification free of charge.

Please submit your CAS details here and for any specific queries reach out to our Regulatory Expert, Ketki Kulkarni at ketki@in.gpcregulatory.com 

What happens if you miss this inventory notification deadline?

If your substance is not present in the inventory (notified by someone else) then it will be considered as new and will be subject to the submission of a comprehensive study of the properties with a chemical safety report.