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Editor-in-chief: Maurizio Roncaccia

Editors: Paul Trouth and Päivi Jokiniemi

Article related to: Communicating about safety

Joining forces to improve downstream users' understanding of EU chemicals legislation

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CheMI represents the interests of EU downstream users whose main activity is to incorporate substances and mixtures into articles. It operates as a platform to share information on REACH-related developments and to express the voice of its members on common interests.

CheMI helps to make sure that European article producers are well informed about their role and obligations as downstream users under REACH. It supports them in their tasks to manage the safe use of chemicals in the workplace and to communicate relevant information to customers, including consumers.

Exchanging information

The platform participates in several high level groups set up by the European Commission and ECHA, including the meeting of the Competent Authorities for REACH and CLP (CARACAL), the Directors' Contact Group and the Exchange Network on Exposure Scenarios (ENES). It operates with a minimum of overhead and on a subscription-free basis, using load sharing to achieve its objectives.

Laetitia Reynaud.
Image: CheMI

The representation of CheMI in these groups helps members to stay aware of any ongoing EU debates and initiatives. The small and medium-sized enterprises (SMEs) particularly need all the relevant information to help them fulfil their responsibilities under REACH.

CheMI members meet face-to-face around three times a year. They exchange information on applying and interpreting the regulation. Experts are frequently invited to these meetings to talk about specific issues.

One of the most recent discussions in the platform was on the European Court of Justice ruling from 10 September 2015 on substances of very high concern (SVHCs) in articles. A member of the group followed the issue and communicated the final decision to the rest of the group. CheMI members discussed the outcome and exchanged views on the interpretation for different articles manufactured by CheMI members.

As a result, all were better informed and had a better understanding of the ruling. It is then up to each sector to individually prepare appropriate communication to its membership, considering the specificities of the sector.

CheMI is now supporting ECHA as an active participant in the Partner Expert Group, which is updating the Guidance on requirements for substances in articles.

CheMI members have also participated in discussions organised by ECHA on possible ways to improve knowledge and communication through the supply chain about substances ending up in articles, such as a Materials Information Platform (MIP).

Voicing concerns

CheMI's presence in the high-level groups also enables regulators to stay up-to-date with industry.

Through these meetings, authorities get a better understanding of the specific issues of article producers, such as the communication obligations and consumers' right to know about substances in articles (Article 33 of REACH). For the latter, CheMi has highlighted the challenges of supply chain communication for complex products - in particular when it involves long, global supply chains.

In addition, CheMI members have insisted on the need to ensure a consistent enforcement of the REACH obligations by EU producers and importers of articles. At present, certain processed chemicals, which are not allowed in the EU, may not be identifiable in imported articles. This, unfortunately, puts EU production at a competitive disadvantage and could lead to further deindustrialisation in the EU, if not properly tackled. Overall, there can be unforeseen consequences of chemical legislation on the daily business of downstream users. It is vital that downstream users can voice their position both in the legislative process and later at the implementation phase of the EU legislation. CheMI is a facilitator to achieve this goal.

Workplace safety

The safe use of chemicals at the workplace is a key concern for CheMI companies. REACH has helped improve communication between companies, suppliers and users of chemicals.

However, the way workplace safety is currently addressed at European level should be reassessed. When substances are found to have risks limited to the workplace, the use of occupational health and safety legislation should be considered.

CheMI has recently joined the Cross Industry Initiative (CII) that promotes a better interaction between REACH and workplace legislation.

Further information:

CheMI - European Platform for Chemicals Using Manufacturing Industries

CheMI's members are European trade associations, which represent a variety of manufacturing sectors. The current 18 member associations represent approximately 400 000 companies, employing more than 7 million employees and generating a turnover of €600 billion. A large majority of the companies represented by CheMI are SMEs. They make a wide variety of products including tyres and rubber articles, woodworking, ceramics, nonwovens, textiles and clothing, toys, leather and footwear, packaging and other printed products.

In general, these companies do not manufacture substances or formulate mixtures. However, they are major users of chemicals in the form of dyes, inks, coatings, adhesives, solvents and additives.

Membership of CheMI is open to any European association representing article producers willing to exchange their knowledge on REACH-related matters with fellow industry sectors. More recently, the group has also covered the interpretation of the Biocidal Products Regulation.

CheMI

http://www.intergraf.eu/chemi.html

Text by Laetitia Reynaud, CheMI