Regulatory Newsletter – November 2022

Is your chemical supply chain prepared for the regulatory changes coming in 2023?

We expect to see many changes to the world of regulatory affairs in 2023. These are likely to include increase in enforcement actions and further actions to support the Chemicals Strategy for Sustainability (CSS).

Our webinar poll?showed that 47% of attendees did not know about CSS!?If you missed the webinar, you can access it?here.?If you are still unsure of CSS's impact on your business, please email us [email protected]?and our experts will be happy to help.

As an example, new classifications for endocrine disrupting, PBT/vPvB and PMT/vPvM properties are being considered for inclusion in the EU CLP Regulation to support the aims of the CSS. This could mean you will need to update your SDSs, Labels, REACH dossiers and poison centre notifications.

Here are a few resources to help you understand and comply with the?coming changes:

• On-demand webinar?on how to achieve regulatory compliance in 2023.
• Infographic on maintaining European compliance?with easy to follow steps.
• Horizon scanning and compliance reporting tool.

Our team is preparing for the potential impact of these changes and can help you navigate the complexities of the changing regulatory world and significantly reduce your compliance costs.

Meet our expert – Caroline Raine, Technical Director Regulatory

Caroline is a chemical legislation expert with?over 15 years of experience in the regulatory world and leads the entire NCEC regulatory offering. Clients find Caroline's depth of expertise, support, bespoke advice and guidance on regulatory matters invaluable for managing their obligations.

Caroline has experience of interpreting and implementing EU legislation relating to hazardous chemical substances. Her wide ranging knowledge and expertise covering both supply and transport legislation was?developed whilst working directly in the chemical industry and through consultancy projects. Caroline is a qualified Dangerous Goods Safety Advisor (DGSA) for the transport of hazardous goods by road and rail, and holds a post graduate certificate in REACH management.

Say hello to Caroline Raine

You have just over 30 days left until all EU SDSs must be updated to new Annex II requirements!

Our recent regulatory webinar showed that 25% of businesses still need to update their EU SDSs.?All EU SDSs must be updated to the new REACH Annex II requirements before 31 December 2022. Watch on-demand webinar on how REACH Annex II impacts your SDS

NCEC offers a fully outsourced and multilingual SDS authoring service, which requires minimal client input/resources to leave you free to concentrate on running your business operations. We have a team of trusted SDS experts, who are already supporting a wide range of clients with their compliance issues and SDS training courses for those authoring in-house. You can find out more on our dedicated?SDS webpage?or contact us [email protected].

Below are the seven things you need to change/update in your EU SDSs immediately to maintain compliance:

• Include?UFIs?assigned to hazardous mixtures for industrial use and to unpackaged mixtures.
• State if a substance is present as a?nanoform.
• State if a substance has an?endocrine disrupting?property.
• Include properties, such as M-factor, from?Annex VI of the CLP.
• Disclose ingredients that trigger the supplementary?hazard statement EUH208.
• Disclose non-hazardous and classified mixtures.
• Closely align with the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), including the?mandatory inclusion of a telephone emergency response number. Our?market leading telephone emergency response service?provides advice, not just information.

More details on all of these changes can be found?here.???

We strongly recommend that you do not delay the process of updating your SDSs, with the support of SDS experts, so that you remain compliant with UK and EU REACH and avoid any disruption to your operations.

Do you need to act? Iceland, Liechtenstein and Norway must now notify to the SCIP database

On 25 October, the European Chemicals Agency (ECHA) announced that the Waste Framework Directive amendment is being extended to the European Economic Agreement. This means that Iceland, Liechtenstein and Norway will now be required to notify under the SCIP database. Find out more our key SCIP database notification services.

ECHA has been receiving notifications from these countries since 7 November. If you are unsure about your SCIP notification obligations, find out?here?the likely scenarios where you will need to take action.

Remember, all articles and products to be placed on the EU market that contain a substance of very high concern (SVHC) at a concentration above 0.1% (weight by weight) must be notified to the SCIP database. Products in scope are required to be notified to the public database under the Waste Framework Directive.

Ricardo offers sustainability support for the chemical sector

Is your business taking action to become sustainable? With investors, consumers and regulators demanding that chemical businesses, not only have tangible sustainability and ESG (Environmental, Social and Governance) targets, but credible data-driven business transition plans that outline how to meet those targets, starting your sustainability journey is a business imperative.

Ricardo, the parent company for NCEC, has deep chemical sector knowledge within our sustainability teams and we combine this with industry-leading expertise to help chemical organisations tailor solutions to cover all aspects of sustainability, from decarbonisation to environmental toxicology.?Please?get in touch?to see how Ricardo’s experts can best help you on your sustainability journey.

To speak with a member of our team regarding assistance with regulatory compliance, emergency response or sustainability, please contact us at [email protected] or visit our website.