ECHA

The REACH and CLP Regulations are not only impacting Europe but also have a strong impact on other continents including Asia. Increased costs and trade disadvantages are matters that are frequently raised. However, many Asian countries are reviewing and rewriting their chemical policies and regulations, and using REACH as the model. Thanks to this, public health and the environment are both likely to improve in Asia.

Korea is about to introduce a so called K-REACH, the Registration and Evaluation of Chemical Substances Act, a similar piece of legislation to the European REACH Regulation. The Japanese chemicals regulation is also being reviewed. Both Japanese and Korean representatives visited ECHA this spring to learn more about how ECHA implements the REACH and CLP Regulations.

India, on the other hand, recently published a Draft National Chemical Policy that aims to consolidate the multiple legislation in India into one law. Currently, there are 15 acts and 19 rules that relate to chemical policies. The new policy sees the European REACH Regulation as a model and aims for the safe use of chemicals and protection of human health and the environment.

We interviewed Japanese, Korean and Indian Experts, Mr Yul-Beom Lee, Director of Chemicals Management Division, Ministry of Environment of Korea; Dr Sanghun Kim, Team Leader of Chemical Management Lab, Korean Institute of Science and Technology in Europe (KIST Europe), Global Knowledge Research Centre; Mr Tomohiro Tsunemi, Chief Officer, Chemical Management Policy decision, Manufacturing Industries Bureau, Ministry of Economy, Trade and Industry, Japan, and his colleagues; and Mr Shisher Kumra, Executive Director, SSS Sustainable Support Services (Europe) AB, Lund, Sweden.

What is the impact of the REACH and CLP Regulations in your country and its industry?

Mr Yul-Beom Lee.

>> Mr Yul-Beom Lee, Korea

We want to learn from the experiences in the European Union because REACH is the globally most important system. Therefore, we are creating a K-REACH in Korea which will be similar to the EU-REACH. We are also thinking of some additional features to the K-REACH for instance helping companies that have difficulties in sharing trade information. The drafting is planned to be completed in 2013 and the law planned to take effect in 2015, but before this the political decision making process also has to be completed. The law in Korea will affect approximately 2 000 substances and 3 000 companies depending on the legal provisions.

>> Dr Sanghun Kim, Korea

REACH is quite complicated and difficult to understand for non-EU companies. ECHA has also not given definite answers concerning for instance exposure scenarios, communication issues in the supply chain or nanomaterials. Therefore, we sometimes have difficulties in meeting the requests of our customers or downstream users. ECHA provides sufficient information for European stakeholders, but non-EU companies feel disadvantaged.

However, our industry's mind is changing towards health, safety and environment. Many companies have already invested in REACH compliance, established internal IT systems and enlarged a responsible organisation. But, in order to improve our national human and environment safety management and keep up with the global trend of chemicals regulation, the Korean government is preparing a new chemicals regulation.

>> Mr Tomohiro Tsunemi , Japan

The REACH and CLP Regulations have had a great impact on the Japanese industry. We have developed our own risk assessment scheme by referring to REACH technical guidance documents and the data on REACH and CLP dossiers on ECHA's website. Especially the data on hazardous substances is a very important and useful information source. METI is one of three Ministries that work in the field of chemicals regulation and the National Institute of Technology & Evaluation provides technical support to enforce the regulation. METI has now started to consider reviewing the Japanese chemicals management system. We are looking at other countries' regulations and we came to ECHA to learn more and to get ideas for our own regulation.

Representatives from Japanese ministries visited ECHA in March 2012.

>> Mr Shisher Kumra, India

Indian industry saw REACH & CLP as technical barriers at first, but on the initiative of Sustainable Support Services as well as the Confederation of Indian Industry (CII), events were organised across the country to create awareness and capacity for REACH compliance. These and other activities lead to Indian industry being better REACH-prepared.

However, Indian SMEs and micro companies faced many problems and had real difficulty in deciding whether or not to invest in REACH compliance. The high costs make it less cost competitive to act on the EU market. EU downstream users could also think that it is easier to buy from EU producers rather than import. In India, production is also often labour intensive and it is difficult to get the discounted registration fee as the head count in India will never be the same as in Europe. But, since the compliance requirements on articles are much lower than on chemical substances, certain uses of chemicals in Europe for the production of articles have moved to countries like India and China, and articles are now imported to the EU. Thus, some Indian companies have moved up in the supply chain ladder.

In 1984, India witnessed the Bhopal-catastrophe and there are also other chemical related accidents that take place sporadically. Therefore, a robust chemical management regulation is needed. It will be advantageous for the Indian industry to comply with one regulation rather than many and it will be easier for the government to regulate and manage one regulation. Needless to say, the Indian population will benefit from better regulated chemicals.

Text and interviews by Pia Fallström Mujkic