Thoughts on Chemical Enterprises' Response to REACH Regulations
In recent years, the international trade situation has become increasingly severe, and foreign technical trade measures have become increasingly strict. Due to the impact of trade technology barriers, a large number of export commodities have not lost their competitive advantage due to the increase of export costs, and the phenomenon of being returned, detained and destroyed is not uncommon.
As is known to all, the EU Regulations on Registration, Evaluation, Authorization and Restriction of Chemicals ("REACH") has been formally implemented. According to the requirements of the regulation, the European Commission will establish a unified chemical monitoring and management system and complete the management of all relevant chemicals by 2012. Compared with the directives implemented by the European Union in recent years, REACH has a broader scope of influence. It will include approximately 30,000 kinds of chemical products in the EU market and their downstream textile, light industry and pharmaceutical products, respectively, for registration, evaluation and licensing. Three management monitoring systems, products not included in the management system cannot be sold in the EU market.
After the implementation of the REACH Regulation, chemical substances, preparations or articles containing chemical substances must be registered with the newly established European Chemicals Agency and obtained technical documents before they can be introduced to the market. For imported goods, registration must be completed by the importer. According to the timetable set by the European Union, chemical substances with an annual output or import volume of more than 1,000 tons should be registered within the next three years; chemical substances with an annual output or import volume of 100-1000 tons should be registered within 6 years; annual output Or chemical substances imported from 1 to 100 tons are registered within 11 years, and products that fail to be registered on time cannot be sold on the EU market. At the same time, the regulations also stipulate strict testing standards and high testing costs, all of which are borne by the company. According to the EU estimates, the basic testing cost of each chemical substance is about 85,000 euros, and the testing cost of each new substance is about 570,000 euros.
In recent years, foreign technical measures to limit toxic and harmful chemical elements have been surging, but these measures are often directed at downstream products that use or add chemical products. Such as food, plant products and toys, clothing, etc. The REACH regulation has pushed many chemical companies to the forefront of the trade war. Most export chemical companies have no awareness and ability to resist foreign technical barriers, so they may be caught off guard when they are "blocked" by foreign technical barriers.
Most of China's export chemical products are illegal inspection products, resulting in less contact with inspection and quarantine. Based on objective reasons, little is known about the promulgation of import and export trade information and warning notices at home and abroad. If many companies do not know what to do with the REACH regulations, the AQSIQ has opened the only government-focused “REACH Regulations†website (http://reach.tbt-sps.gov.cn). In addition, the competent departments of export chemical enterprises are divided into different industries, and the management methods are not uniform. The above two factors have caused the news of chemical companies to be ineffective, and the channels for obtaining news are not smooth.
There is also a general phenomenon that corporate habits rely on the support of the government and the competent authorities. The area where the author is located is known as the “hometown of chemical industryâ€. Only the chemical development zone has gathered about 100 large and small chemical companies. In order to help enterprises prepare for the situation, understand the awareness of REACH regulations in the region and the impact of REACH regulations, follow the survey of relevant companies in September last year, and continue to conduct investigations on export chemical companies in light of the usual work. Work at the bottom. Among the companies surveyed, there are collectives, individuals and foreign investors. Almost all companies have products exported to EU countries or regions. However, the results are not optimistic. In the column of “How to deal with the REACH Directiveâ€, 80% of the enterprises fill in the content: report to the inspection and quarantine institution in time, and hope that the government agencies will negotiate. The main and objective reasons indicate that the implementation of REACH will make China's chemical trade crisis in Europe and Europe a serious crisis. Therefore we recommend:
First, improve China's chemical management regulations, and gradually integrate with foreign chemical management systems. Drawing on the requirements of EU chemical registration, assessment and licensing, we will establish a chemical management regulation that suits China's national conditions as early as possible, in order to protect the health and ecological environment of our people, protect and improve our national industry. The main regulations for chemical management in China are the Regulations on the Management of Hazardous Chemicals issued by the State Council. The export of hazardous chemicals is mainly based on the requirements of the Commodity Inspection Law and some international rules. Although other departments also have a small number of regulations, they do not match each other. The United States, the European Union, Japan and other countries have more than 10 chemical safety management legislation. And the responsibilities are clear and the operability is strong.
Second, the competent government departments must work hard to carry out their work. First, we must increase publicity, publicize the content of the REACH Directive, the work that the company should do, and the impact of the implementation of the REACH Directive, organize industry associations and related companies to carefully study countermeasures, and prepare to minimize the impact. . Second, we must actively coordinate the counterparts in the higher authorities, and provide technical assistance to enterprises before and during the implementation of the REACH regulations. For example, the progress and impact of the implementation of REACH regulations provide relevant data information for enterprises, such as export cost data and test data, etc.; regularly publicize relevant laws and regulations, new standards and other information released at home and abroad to help enterprises improve products. Competitiveness.
Third, industry associations should establish a sound early warning system and play a full role in the process of responding to REACH regulations. It is necessary to establish an effective communication and coordination mechanism between the government and enterprises. Actively participate in the propaganda work before the implementation of the REACH Regulations, and use the advantages of intermediary organizations to provide enterprises with more updated information on chemical safety management information and organize enterprises to respond. Measures. After the formal implementation of the REACH system, the company will organize the unified registration and inspection cost sharing to reduce the registration and testing costs of each enterprise.
4. The enterprise is the subject of the REACH regulations. A key feature of the new EU regulations is the transfer of more responsibility for controlling chemical risks from management to business. Export chemical companies should fully understand the specific contents of REACH regulations and technical guidelines, actively collect information, attach importance to the impact and impact on the enterprise after the implementation of the regulations, abandon the concept of dependence and indifferent, and take early measures. First, communicate with the importer in advance and do a good job. Since REACH requires registration by natural or legal persons within the EU, companies can register through legal entities established within the EU through domestic intermediaries, or through their own stable trading partners within the EU. Complete the relevant registration business. Second, we must promptly prepare relevant information. According to the requirements, the information required for enterprise registration includes chemical safety data sheets, chemical safety reports, risk management measures for determining the use, physical and chemical data of the substances themselves, etc., and as the registration work is carried out, the content to be provided will become more and more detailed. However, many companies' products lack relevant data and do not meet the basic registration requirements of REACH. Therefore, chemical companies should pay close attention to all the chemicals produced and exported by the company, determine the types of these chemicals according to the requirements of REACH, and prepare relevant technical materials for pre-registration and registration according to different categories to meet Registration after REACH implementation is required. Third, we must strengthen horizontal linkages between enterprises, and we can actively establish cooperative relations with domestic and foreign counterparts, advanced chemical companies at home and abroad, and cooperate with relevant EU advisory bodies to obtain information support in a timely manner. Fourth, we must establish a whole process management mechanism from production to sales in accordance with REACH regulations to ensure that enterprises operate in accordance with the requirements of the REACH system. Efforts should be made to adopt international standards to organize production, adopt high-tech and clean production processes, accelerate the adjustment of industrial structure and product structure, improve product quality and grades, and strive for export initiative to avoid adverse competition for products after the implementation of REACH regulations.
As is known to all, the EU Regulations on Registration, Evaluation, Authorization and Restriction of Chemicals ("REACH") has been formally implemented. According to the requirements of the regulation, the European Commission will establish a unified chemical monitoring and management system and complete the management of all relevant chemicals by 2012. Compared with the directives implemented by the European Union in recent years, REACH has a broader scope of influence. It will include approximately 30,000 kinds of chemical products in the EU market and their downstream textile, light industry and pharmaceutical products, respectively, for registration, evaluation and licensing. Three management monitoring systems, products not included in the management system cannot be sold in the EU market.
After the implementation of the REACH Regulation, chemical substances, preparations or articles containing chemical substances must be registered with the newly established European Chemicals Agency and obtained technical documents before they can be introduced to the market. For imported goods, registration must be completed by the importer. According to the timetable set by the European Union, chemical substances with an annual output or import volume of more than 1,000 tons should be registered within the next three years; chemical substances with an annual output or import volume of 100-1000 tons should be registered within 6 years; annual output Or chemical substances imported from 1 to 100 tons are registered within 11 years, and products that fail to be registered on time cannot be sold on the EU market. At the same time, the regulations also stipulate strict testing standards and high testing costs, all of which are borne by the company. According to the EU estimates, the basic testing cost of each chemical substance is about 85,000 euros, and the testing cost of each new substance is about 570,000 euros.
In recent years, foreign technical measures to limit toxic and harmful chemical elements have been surging, but these measures are often directed at downstream products that use or add chemical products. Such as food, plant products and toys, clothing, etc. The REACH regulation has pushed many chemical companies to the forefront of the trade war. Most export chemical companies have no awareness and ability to resist foreign technical barriers, so they may be caught off guard when they are "blocked" by foreign technical barriers.
Most of China's export chemical products are illegal inspection products, resulting in less contact with inspection and quarantine. Based on objective reasons, little is known about the promulgation of import and export trade information and warning notices at home and abroad. If many companies do not know what to do with the REACH regulations, the AQSIQ has opened the only government-focused “REACH Regulations†website (http://reach.tbt-sps.gov.cn). In addition, the competent departments of export chemical enterprises are divided into different industries, and the management methods are not uniform. The above two factors have caused the news of chemical companies to be ineffective, and the channels for obtaining news are not smooth.
There is also a general phenomenon that corporate habits rely on the support of the government and the competent authorities. The area where the author is located is known as the “hometown of chemical industryâ€. Only the chemical development zone has gathered about 100 large and small chemical companies. In order to help enterprises prepare for the situation, understand the awareness of REACH regulations in the region and the impact of REACH regulations, follow the survey of relevant companies in September last year, and continue to conduct investigations on export chemical companies in light of the usual work. Work at the bottom. Among the companies surveyed, there are collectives, individuals and foreign investors. Almost all companies have products exported to EU countries or regions. However, the results are not optimistic. In the column of “How to deal with the REACH Directiveâ€, 80% of the enterprises fill in the content: report to the inspection and quarantine institution in time, and hope that the government agencies will negotiate. The main and objective reasons indicate that the implementation of REACH will make China's chemical trade crisis in Europe and Europe a serious crisis. Therefore we recommend:
First, improve China's chemical management regulations, and gradually integrate with foreign chemical management systems. Drawing on the requirements of EU chemical registration, assessment and licensing, we will establish a chemical management regulation that suits China's national conditions as early as possible, in order to protect the health and ecological environment of our people, protect and improve our national industry. The main regulations for chemical management in China are the Regulations on the Management of Hazardous Chemicals issued by the State Council. The export of hazardous chemicals is mainly based on the requirements of the Commodity Inspection Law and some international rules. Although other departments also have a small number of regulations, they do not match each other. The United States, the European Union, Japan and other countries have more than 10 chemical safety management legislation. And the responsibilities are clear and the operability is strong.
Second, the competent government departments must work hard to carry out their work. First, we must increase publicity, publicize the content of the REACH Directive, the work that the company should do, and the impact of the implementation of the REACH Directive, organize industry associations and related companies to carefully study countermeasures, and prepare to minimize the impact. . Second, we must actively coordinate the counterparts in the higher authorities, and provide technical assistance to enterprises before and during the implementation of the REACH regulations. For example, the progress and impact of the implementation of REACH regulations provide relevant data information for enterprises, such as export cost data and test data, etc.; regularly publicize relevant laws and regulations, new standards and other information released at home and abroad to help enterprises improve products. Competitiveness.
Third, industry associations should establish a sound early warning system and play a full role in the process of responding to REACH regulations. It is necessary to establish an effective communication and coordination mechanism between the government and enterprises. Actively participate in the propaganda work before the implementation of the REACH Regulations, and use the advantages of intermediary organizations to provide enterprises with more updated information on chemical safety management information and organize enterprises to respond. Measures. After the formal implementation of the REACH system, the company will organize the unified registration and inspection cost sharing to reduce the registration and testing costs of each enterprise.
4. The enterprise is the subject of the REACH regulations. A key feature of the new EU regulations is the transfer of more responsibility for controlling chemical risks from management to business. Export chemical companies should fully understand the specific contents of REACH regulations and technical guidelines, actively collect information, attach importance to the impact and impact on the enterprise after the implementation of the regulations, abandon the concept of dependence and indifferent, and take early measures. First, communicate with the importer in advance and do a good job. Since REACH requires registration by natural or legal persons within the EU, companies can register through legal entities established within the EU through domestic intermediaries, or through their own stable trading partners within the EU. Complete the relevant registration business. Second, we must promptly prepare relevant information. According to the requirements, the information required for enterprise registration includes chemical safety data sheets, chemical safety reports, risk management measures for determining the use, physical and chemical data of the substances themselves, etc., and as the registration work is carried out, the content to be provided will become more and more detailed. However, many companies' products lack relevant data and do not meet the basic registration requirements of REACH. Therefore, chemical companies should pay close attention to all the chemicals produced and exported by the company, determine the types of these chemicals according to the requirements of REACH, and prepare relevant technical materials for pre-registration and registration according to different categories to meet Registration after REACH implementation is required. Third, we must strengthen horizontal linkages between enterprises, and we can actively establish cooperative relations with domestic and foreign counterparts, advanced chemical companies at home and abroad, and cooperate with relevant EU advisory bodies to obtain information support in a timely manner. Fourth, we must establish a whole process management mechanism from production to sales in accordance with REACH regulations to ensure that enterprises operate in accordance with the requirements of the REACH system. Efforts should be made to adopt international standards to organize production, adopt high-tech and clean production processes, accelerate the adjustment of industrial structure and product structure, improve product quality and grades, and strive for export initiative to avoid adverse competition for products after the implementation of REACH regulations.
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