UK REACH – Preparation of RMOAs
Health and Safety Executive (HSE) opened a call for evidence on 4 substances and substance groups. These 4 substances have recently been identified as SVHCs by the EU. HSE and Environment Agency, is preparing Risk Management Option Analysis (RMOAs) for the substances and substance groups below. To inform these RMOAs, HSE has opened calls for evidence. They also invited interested parties to respond with general information and information on specific topics. DOTL: All dioctyltin dialurate, stannane, dioctyl-, bis(coco acyloxy) derivatives, as well as all other stannane, dioctyl-, bis(fatty acyloxy) derivatives. wherein C12 is the predominant carbon number of the fatty acyloxy moiety.The common CAS numbers are 3648-18-8 and 91648-39-4 derivaties. DOTL is used as a catalyst in the manufacture of a variety of polyurethane applications, varnish and powder coatings and sealants. DOTL based products are also used to catalyze processes for manufacturing polyester polyols and other polyester products such as the cross-linked low-density polyethylene cable insulation that is used for communications applications. 1,4-dioxane: 1,4-Dioxane can be found/used s a solvent in the production of lacquers, varnishes, cleaning and detergent preparations, adhesives, cosmetics, deodorant fumigants, emulsions and polishing compositions, pulping of wood, extraction medium for animal and vegetable oils, laboratory chemicals (eluents in chromatography), cassettes, plastic, rubber, and insecticides. Small brominated alkylated alcohols (SBAA) has 3 substances: 2,2-bis(bromomethyl)propane1,3-diol (BMP) (CAS number 3296-90-0)- used as a reactive flame retardant in polymer resins 2,2-bis(bromomethyl)propane1,3-diol (BMP) (CAS number 3296-90-0)- used as a reactive flame retardant in polymer resins 2,2-bis(bromomethyl)propane1,3-diol (BMP) (CAS number 3296-90-0)- used as a reactive flame retardant in polymer resins PDDP: Phenol, alkylation products (mainly in para position) with C12-rich branched or linear alkyl chains, covering individual isomers and combinations thereof. This group has below listed chemicals: Phenol, 4-isododecyl – (CAS no: 27459-10-5) Phenol, tetrapropylene – (CAS no: 57427-55-1) phenol, 4-dodecyl – branched (CAS no: 210555-94-5) phenol, (tetrapropenyl) derivatives (CAS no: 74499-35-7) Phenol, 4-isododecyl – (CAS no: 27147-75-7) Additional substance names listed without CAS number assigned, include: Tetrapropenyl phenol 4-(3,4,5,6-tetramethyloctan-2-yl) phenol 4-(3,4,5-trimethylheptyl) phenol Phenol, alkyl branched (species comprising decyl, undecyl, dodecyl, tridecyl, tetradecyl, pentadactyl, substituents) Phenol, para-alkylation products with C12-rich branched olefins from propene oligomerization The main use for PDDP is as a chemical intermediate in the production of lubricant additives, hydraulic oils and fuel system cleaners, synthetic rubbers, tires and floor coatings, paints, printing inks, varnishes, epoxy and phenolic resins. The call for evidence of all 4 substances will close on 10th April. These RMOAs will assess the most appropriate regulatory approach for these substances and substance groups in Great Britain. It is their responsibility to determine the use profile of each substance and substance group in Great Britain, to identify whether any of these uses pose a risk to human health and/or the environment, and to identify the best regulatory approach to address any risks identified.
HSE published a list of Substances grandfathered under UK REACH
The UK REACH Regulation for safety of chemicals includes an article 127B(4)(a) in which a list of names of substances with their CAS/EC numbers is compiled based on notifications. Article 127B(4)(a) of UK REACH requires registrants of former EU REACH registrations to provide HSE with basic information about their registration (“initial transitional data”). Using the Comply with UK REACH service, this initial transitional data was submitted to HSE. The list includes data that have been provided up until and including 1 July 2021. There can be no guarantee that the information on the list is accurate since it was compiled from initial transitional data. It is worth noting that the list does not include all substances registered under EU REACH that have been transferred to UK REACH under the Article 127A(1) (transferred registrations). In the event that a transfer of registration occurs, the substance will not appear on the list if: It has not been submitted any initial transitional data; The initial transitional data was sent as confidential by those who submitted it Similarly, if a substance is imported solely by a new registrant or an ex-downstream user or distributor, it will not be included on the list. Before the end of the transition period, all UK-based companies that were downstream users or distributors of EU REACH products are required to inform the HSE that they are downstream users and distributors by submitting a Downstream User Import Notification (DUIN). As a result, the importers won’t have to pay registration duty anymore. The DUIN needs to be submitted before 27 October 2021.
Everything about UK REACH and How to Comply
United Kingdom’s (UK) Chemicals regulatory framework (UK REACH) is effective from 1st January 2021. United Kingdom (UK) will no longer be a part of European Chemicals Agency (ECHA) or the European (EU) regime from the 1st January 2021. Instead UK will have new REACH system for the Registration, Evaluation, Authorization or Restriction of Chemicals (REACH). All manufactures and distributes of chemicals (Substances or Mixtures) in UK need to comply with the new regulatory framework for chemicals. All the manufacturers and importers of the UK market are required to register their chemicals under UK REACH system. The registration of EU REACH regime will no longer be valid to do business in UK market. Chemical manufacturers and importers need to transfer their registration to an EU/EEA-based organization. EU REACH registrations held by the UK based companies will carry across directly into UK REACH. The UK based companies need to submit their basic information to UK’s Health and Safety Executive (HSE) by 30th April 2021, using the UK REACH IT system, ‘Comply with UK REACH’, from 1stJanuary 2021. A company that is currently importing chemicals from an EU/EEA country and do not hold an EU REACH registration need to ensure that the chemicals (substances or mixtures) purchased are covered by a valid UK REACH registration. UK based companies holding EU REACH registration can continue exporting chemicals (substances or mixtures) to EU/EEA markets by transferring their registration to an EU/EEA based entity or their importers can be a registrant of EU REACH. A company can get more information from The European Chemical Agency (ECHA) explaining how to transfer their UK held EU REACH registrations before 1st January 2021. If an EU/EEA based company is importing chemicals into UK, the company is required to have a valid UK REACH registration. The registration can be done through their UK entity or through UK importer. If the EU/EEA company has any kind of obligations on registration through a UK based entity, their UK customers will retain their downstream user status. Talk to a Global Compliance Specialist today!