Chemical Watch EXPO Berlin, Germany, April 25 th 26 th, Dr. Michael Cleuvers, Managing Director Industrial Chemicals & Biocides

Transcription

1 Chemical Watch EXPO Berlin, Germany, April 25 th 26 th, 2017 Dr. Michael Cleuvers, Managing Director Industrial Chemicals & Biocides 1

2 Integrating REACH compliance with global compliance Developments in East-Asia EU China Taiwan Korea Thailand Malaysia Vietnam Philippines Indonesia 2

3 Agenda Introduction / Background Types of legislations / Inventories Data requirements Brief examples, overview about - China - Korea - Taiwan - Thailand GHS implementation Summary 3

4 4 A look back: World Summit on Sustainable Development (WSSD), Johannesburg 2002 Political commitment on the goal to achieve: «By 2020, chemicals are used and produced in ways that lead to the minimization of significant adverse effects on human health and the environment»

5 5 National policy development around the world United Nations Environment Programme (UNEP): framework for national chemical management 1. Information access, data availability 2. Policy and planning 3. Laws 4. Institutions 5. Implementation and enforcement capacities 6. Public participation

6 6 National policy development Levels of national policy development: Level 0: Level 1: Level 2: Level 3: almost no capacity exists limited information available, needs identified, constitutional resources exist, clear mandates for ministries, chemicals integrated in national policies, comprehensive legislation exist all elements have been fulfilled (e.g. EU-REACH)

7 What do we need to get there? Summary of recommendations (OECD) Increase cooperation and mutual acceptance of data Improve understanding of adverse effects of chemicals on individuals and populations and better quantify sources of exposure More preventative action to avoid harm from chemicals Promote sustainable use of chemicals Improve the public s right to know Improve enforcement of regulations

8 Opportunities to share information Huge amount of data is made publicly available on ECHA's website accessible to other countries International cooperation is expressly foreseen in REACH. ECHA has signed bilateral co-operation agreements with agencies in Canada, Australia, Japan, US EU is engaged in (negotiations for) a range of bilateral agreements and dialogues that also concern chemicals (e.g. South Korea FTA, Japan, China) EU is committed to multilateral work in OECD, UN No obstacles in principle for information sharing safeguards necessary for protection of CBI 8

9 The global perspective

10 Source: Cefic: The European chemical industry, Facts & Figures 2013, 10

11 Important initial questions to answer if you want to sell your chemical products globally What kind of regulation is existing in my target markets? - New chemicals, existing chemicals, hazardous chemicals? Only chemical inventories to check? Registration necessary? Different types? Exemptions? Rules for Classification and labelling? Data requirements? National specialities? What is my REACH data package good for?

12 What about. Starting position and initial considerations Your substance? Identity, composition, properties, form in the supply chain Your position in the supply chain? Different obligations for different actors Your needs and obligations? Tonnage band, data requirements, uses Your budget? Different scenarios (short term / long term)

13 Scope of chemical management schemes EU-REACH: All chemicals (unless exempted) above 1 t/a (new and existing, hazardous and non-hazardous) Only new chemicals: MEP Order No. 7 (China), TSCA (USA), NSN (Canada) Only hazardous chemicals (new and existing): Decree 591/SAWS Order No. 53 (China), EHSNR (Malaysia) New chemicals and selected existing chemicals: AREC (Korea), TCSCA (Taiwan)

14 Starting point A company which develops a new substance and wants to market it in several countries, has to follow different legislations with different data requirements. Additionally, as many countries have their own chemicals inventories, often a substance is considered to be an existing one in country A but a new one in country B, which may trigger unexpected requirements. For example, needless to say that the Chinese IECSC is not equivalent to EINECS!

15 EINECS vs IECSC There are about substances on EINECS, and even substances have been preregistered as phase-in substances under REACH. However, only about substances are listed on the inventory of existing chemical substances in China (IECSC). All chemical substances not listed in Inventory of Existing Chemical Substances in China (IECSC) are new chemical substances and subject to notification! While most commodities may be listed on IECSC, many other substances may be identified as new substances, especially specialty chemicals or high tech products imported from western countries.

16 Chinese inventory (IECSC) In China alone there is room for thousands of misconceptions! Thus, it is very important to check all relevant inventories. This is of particular importance because manufacturers and/or importers of new substances have to submit new substances notification before these substances are offered on the market and there are strict penalties imposed for non compliance.

17 Matrix for relevant inventories Substance EU China Korea Japan A Listed Listed Listed Listed B Listed Not listed Listed Not listed C Listed Not listed Not listed Listed D Not listed Not listed Not listed Not listed E Listed Listed Listed Listed

18 Data requirements When determining the data requirements, it may come out that you have to perform even more than one test per endpoint (e.g. fish, biodegradation) or additional studies (repeated dose) compared to REACh depending on the target market. Find out in time what are the data gaps and what is the most critical endpoint with regards to costs and timing.

19 Data requirements If you have purchased a REACH Letter of Access: are you allowed to use the data also for other regulations outside of REACH? Is the legal entity who is exporting to Non-EU the same who has purchased the LoA under REACH?

20 Data gap analysis

21 Matrix for Data requirements Example: Tonnage band 1-10 t/a Endpoint (selected) EU A. VII China G. N. Korea F. N. Fish, acute (OECD 203) No No Yes No Fish acute China (OECD 203, local) No Yes No No Biodegradation (OECD 301) Yes No Yes No Biod. Japan (OECD 301C) No No No Yes Biod. China (OECD 301, local) No Yes No No Acute tox, oral (OECD 401, 423) Yes Yes Yes No Acute tox, dermal (OECD 402, 434) No Yes No No Repeated dose toxicity (OECD 407) No Yes No No Japan Low V.

22 Data gap analysis Example: a REACh Annex VII data set is available Endpoint (selected) Existing Data Waiver Readacross, QSAR New study Fish, acute (OECD 203) No No No Yes Fish acute China (OECD 203, local) No No No Yes Biodegradation (OECD 301) Yes Biod. Japan (OECD 301C) No No No Yes Biod. China (OECD 301, local) No No No Yes Acute tox, oral (OECD 401, 423) Yes Acute tox, dermal (OECD 402, 434) No No No Yes Repeated dose toxicity (OECD 407) No No No Yes

23 Data gap analysis Although you have a REACh Annex VII data set and you are in the same tonnage band, there are additional requirements to fulfill if you want to market your substance in Asian markets. Thus, consider this additional effort when you are setting up your marketing & sales strategy (time & money!)

24 Additional data requirements due to a dossier upgrade (tonnage band increase) What to do in the event that sales & marketing forecasts exceed the originally approved notification level? EU: post-exceedance No need to interrupt the substance supply. Applicant informs the authority, discusses and performs additional testing and updates the dossier. China, Japan: pre-exceedance The supply is restricted to the notified tonnage band. Applicant discusses and performs additional testing and updates the dossier before he can increase the supply.

25 Data requirements data acceptance OECD: Mutual Acceptance of Data (MAD): The testing of chemicals is labour-intensive and expensive. Often the same chemical is being tested and assessed in several countries. Because of the need to relieve some of this burden, the OECD Council adopted a decision in 1981 stating that data generated in a Member country in accordance with OECD Test Guidelines and Principles of Good Laboratory Practice (GLP) shall be accepted in other Member countries for assessment purposes and other uses relating to the protection of human health and the environment. But some of your target markets may not be OECD member states or have not yet implemented GLP standards (or have other reasons to deviate from this approach ).

26 Challenging..but invest in sound planning - and you are half way there These new requirements will not go away. Wait and see or hide ar not sustainable approaches Be active!

27 China MEP Order No.7 Decree 591, SAWS Order No. 53 With support from Xiaohua He, 27

28 Chemical management in China New chemical substances registration MEP Order No. 7 (2010) Existing chemicals (IECSC, 2013) Not regulated Hazardous chemicals (HazChem Catalogue 2015) SAWS Order No. 40, 41, 50, 51, 53 and 55 ( ) National standards for GHS implementation (GB 30000) 84 Priority hazardous chemicals catalogue for environment management (2014); MEP Order No. 22 (Trail, 2012) 162 Toxic substances strictly controlled for import and export (T-Catalogue, 2014) MEP Administration Announcement 113 (2014) 28 - Nie, 2012 (modified)

29 Check your duties Yes Your substance is existing? No Check public and confidential parts of IECSC! Your substance is a Restricted Toxic Chemical for Import & Export or listed as Hazardous Chemicals No Yes Your use requires registration under China-Reach? No Yes Arrange new substance registration with your legal representative No registration obligations Import Clearance Notification, Registration Certificate (SAWS Order 53), SDS,.. Check whether other regulations may apply (pesticides, pharmaceuticals,..)

30 Notification types new substances Type of Notification Typical Notification Simplified Notification (basic conditions) Simplified Notification (specific conditions) Scientific Research Record Scope New chemical substances, manufactured / imported > 1 t/a; tonnage based notification levels: 1-10, , , > 1000 t/a New chemical substances, manufactured / imported < 1 t/a New chemical substances, - for export only < 1 t/a - for scientific research t/a - for technological research < 10 t/a - for polymers (if all monomers already listed in IECSC or containing < 2% new chemicals) - for low concern polymers New chemical substances, for scientific research < 0.1 ton or for samples to be tested in laboratories in China

31 Toxicology Data Requirement Level I 1-10 t/a Level II t/a Level III t/a Level IC > 1000 t/a Acute toxicity 28-d repeated dose toxicity Mutagenicity 90-d repeated dose toxicity Reprod./developm. Toxicity Toxicokinetics Chronic toxicity Carcinogenicity

32 Ecotoxicology Data Requirement Level I 1-10 t/a Level II t/a Level III t/a Level IC > 1000 t/a Algal growth inhibition Daphnia acute Fish acute Activated sludge Adsorption/desorption (Bio-)degradability Earthworm acute Fish 14-d prolonged Daphnia reproduction Bioaccumulation Fish chronic Terr. plants

33 Data requirements In Toxicology as well as in Ecotoxicology the Measures are more demanding than REACh. There is no option to include testing proposals first. Some Ecotox-data has to be generated in certified Chinese labs using Chinese test species (e.g. for fish and invertebrate tests). Testing Data are strongly preferred over other types of data. QSARs and Read-Across are helpful for screening purposes, but acceptance by authorities is difficult. For literature data full reports need to be provided (not only abstracts). Expert Statements can be acceptable (case by case).

34 Testing in China In China in some labs you can choose between Chinese GLP (cheaper) and OECD GLP. If you want to use the studies outside of China, OECD GLP is mandatory! Check thoroughly whether you need a study for China only or if you need it also for other jurisdictions.

35 Guidance for new chemical notification and registration (issued end of October, 2016) China s Ministry of Environmental Protection (MEP) has submitted the revised draft new substance guidance on MEP Order No. 7 (draft 2 nd revised, 2016) to the World Trade Organization (WTO) in May Key revised points: Exemptions, Scope of application and Dissemination Registrant and certificate holder Data requirements and waiving conditions Polymer registration and notifcation Risk assessment report Changes or cancellation of certificate 35

36 South Korea Act on the Registration and Evaluation of Chemicals With support from In Woo Kim, 36

37 K-REACH Existing substances 1MT/ y Designated existing substances 1 MT/y or < 1 MT/y for highly hazardous substances Toxic substances Authorization REPORTING (Chemicals & Mixtures) REGISTRATION HAZARD EVALUATION RISK ASSESSMENT Shall be registered before manufacture/importation New substances (all) Restriction/ Prohibition PRODUCTS Notification of Hazardous Chemicals in Products Risk Concerned Products Risk Assessment by MoE Publication of Criteria of Safety/Labeling If violated : Order of withdrawal If no criteria : Submission of risk 37 data

38 Obligations Annual Reporting All new substances and existing substance of 1 t/a should be reported by 30th of June each year. Registration of substances (new and Priority Existing Chemicals (PEC)) Joint registration of PEC substances 1 t/a within 3 years of grace period (Currently 510 PEC substances by June 2018) All new substances before the manufacture/import Product notification Products containing hazardous substance(s) over 0.1 % weight ratio per product and the total amount of the substance is more than 1 t/a. 38

39 Annual reporting Reporting contents Substance name, CAS-No., tonnage band, use category Importer information Country of origin of the substance Attachement OR appointment confirmation certificate by 30th of June each year 39

40 PEC substance registration UNDER REVISION Deadline for 1st batch: June 30th, 2018 Importer Only Rep. Join SIEF Registration through K-REACh IT system Registration confirmation Import /manufacture allowed * Registration confirmation takes up to 30 days, however, in case of late registration (within 2 months before the deadline) it may take up to 3 months! General data requirement Substance information (name, CAS- No., purity, molecular formular, product name, impurities/by-products) Tonnage All uses Product type and content Exposure information related to use Joint registration data requirement Classification & labelling Physicochemical properties Tox & EcoTox data Test plan (if necessary) Risk assessment ( 10 t/a) Guidance on safe use Could be prepared per registrant 40

41 New substance registration Importer Only Rep. Request for registration check of the same substance* Registration Registration confirmation Import /manufacture allowed * In case there was a registration of the same substance, data-sharing for phys-chem and Tox & EcoTox can be requested. New substances must be registered before manufacture / import. Currently low-volume substances (<1 t/a) benefit from data exemption Data exemption: No Phys-chem data, Tox & EcoTox data, risk assessment, guidance on safe use Exempted data should be submitted if available From 2020 data exemption will be applicable only to new substances 0.1 t/a 41

42 Product notification A product means a mixture or an article used by an end user or a component of the mixture or the article that may expose consumers to chemical substances. Content Consumer products containing hazardous substance(s) > 0.1% in weight ratio and > 1 t/a in total amount. Consumers regard to such individuals using the products for consumption or production activities, however, in case they use the products as raw materials to produce another product, the definition of consumer does not apply. The substance is subject to notification along with information on the products. When Before manufacture / import after exceeding the total amount of 1 t that year 42

43 Flowchart products imported into Korea 510 PECs list, if on the list: registration is required List of components in your products imported to Korea Check if on KECI PECs New chemical substance (registration is required) Check if hazardous or not No product notification needed No product notification Contained in needed the product 0,1 % and > 1 t/year? to be notified by manufacturer/importer to local MoE office! 43

44 Future amendments to K-REACH Major changes ahead! Annual Reporting is to be abolished speculated to enter in force from Registration of ALL EXISTING substances (more similar to EU REACH) Introduction of pre-registration for all existing substances > 1t/a Registration deadline depends on the tonnage Product notification Biocidal products are to be regulated under a separate regulation (similar to EU BPR) 44

45 TAIWAN Toxic chemical substances control act With support from Xiaohua He, 45

46 Toxic Chemical Substance Control Act in Taiwan Two Regulations: Regulation of New and Existing Chemical Substances Registration Law/Act Authority Implementation date 11 December 2014 Toxic Chemical Substances Control Act (TCSCA) Taiwan s Environmental Protection Administration (Taiwan EPA) English version of the Regulation of New and Existing Chemical Substances Registration available under: Regulation of New Chemical Substance Registration and Management Law/Act Occupational Safety and Health Act (OSHA) Authority Taiwan s Ministry of Labor (Taiwan MOL) Implementation date 01 January

47 TCSCA New Chemical Substance (NCS) Notification Basics Who: - Domestic (Taiwanese) entities, who manufacture or import. - Companies with no legal entity in Taiwan can apply for chemical substance registration but must do so through a Taiwan-based agent (third-party). No Only Representative. What: Substances not on Inventory or not otherwise excluded When: Since 11 December 2014; 90 days prior to manufacture and import How: Via three types of notification: Standard Registration, hazard & exposure assessments may also be requested Simplified Registration Small Quantity Registration Submission via one joint portal of TCSCA and OSHA now possible. 47

48 TCSCA/OSHA New Chemical Substance (NCS) Registration types MT/yr Polymer of Low Concern 0 Substance for SRD 1 On-site Isolated Intermediate; Polymer; Substance for PPORD 2 Regular NCS CMR 3 0 Small Quantity Registration No Requirements Small Quantity Registration 0.1 Simplified Registration Standard Registration (Level I) 1 Simplified Registration Standard Registration (Level I) Standard Registration (Level II) Small Quantity Registration Standard Registration (Level I) Standard Registration (Level II) ++ Standard Registration (Level III) ++ Standard Registration (Level IV) ++ Standard Registration (Level III) ++ Standard Registration (Level IV) ++ 0 Polymer of low concern: Status needs to be evaluated and verified by Central Competent Authority. 1 SRD: Scientific Research and Development. 2 PPORD: Product and Process Orientated Research and Development. 3 CMR: Substance, which is Carcinogenic, Mutagenic or Toxic to Reproduction. 4 ++: Plus Hazard Assessment and Exposure Assessment. 48

49 Registration of existing substances Phase I Registration - Like a pre-registration under EU REACH. Only company and contact info, substance identification, quantity, and info on manufacture and uses has to be provided. Phase II: Registration of Existing Substances - Standard Registration - EPA will announce the list of designated existing substances subject to standard registration in 4 batches. - Each batch will be given a grace period of 2-3 years. - The first batch was expected to be announced in 2016, but this has been postponed to December 31 st, 2017! - Data requirement is the same as standard registration of new substances. 49

50 THAILAND Hazardous Substance Act B.E (1992) With support from P. Pukclai, 50

51 Current Regulation: Hazardous Substance Act B.E (1992) Proposed Changes 2017 and Beyond 51

52 Hazardous Substance Act B.E (1992) 1 st issued in B.E (1992), revised twice in B.E (2001) and B.E (2008) Under the responsibility of the Ministry of Industry (MOI) Diverse characteristics & usages of substances, enforcement is split over 6 authorities: Department of Agriculture (DOA), Ministry of Agriculture and Cooperatives (MOAC) Department of Fisheries (DOF), MOAC Department of Livestock Development (DLD), MOAC Food and Drug Administration (FDA), Ministry of Public Health (MOPH) Department of Industrial Works (DIW), MOI Department of Energy Business (DOEB), Ministry of Energy (ENERGY) 52

53 Annex Hazardous Substances List B.E (2013) and B.E (2015) Responsible Authority Sub-List 1 DOA 1.1 Discrete Substances 1.2 Groups and classes by properties or uses e.g., Active ingredients intended for preventing, destroying or controlling plant diseases 2 DOF 2.1 Discrete Substances 2.2 Groups 2.3 Classes by properties or uses 3 DLD 3.1 Discrete Substances 3.2 Groups and classes by properties or uses 4 FDA 4.1 Discrete Substances 4.2 Groups 4.3 Classes by properties or uses 5 DIW 5.1 Discrete Substances 5.2 Chemical Wastes 5.3 Used Electrical Equipment and Appliances 5.4 Others 5.5 Chemical Weapons 5.6 Substances and mixtures based on hazard properties* 6 DOEB Natural Gas and Liquefied Petroleum Gas 53 2 Number

54 Notification, Registration & Licensing Procedures All producers, importers, carriers and persons in possession of listed HS must notify, register or submit application of a license at the Hazardous Substances Control Bureau, DIW. HS Type 1 Notification of product information HS Type 2 & 3 (Registration and Licensing (Type 3) Check status of substance via online system and discuss with DIW authorities Submission of application and related documents: 100% composition, MSDS, etc. Checking of application and its dossiers by DIW officers Evaluation process Approval from the authorized officer Issuance of registration certificate HS Type 4 Totally banned For the official DIW guideline, go to: 54

55 New list 5.6 On Feb 19 th, 2015, Ministry of Industry (MOI) published a notification pertaining to the List of Hazardous Substances (No. 2) B.E (2015). According to the notification, manufacturers and importers of chemical substances that meet certain criteria will have to notify chemical substances to the Department of Industrial Works (DIW). By gathering notification information, DIW aims to prepare Thailand s inventory of existing chemicals and determine the appropriate approaches for chemicals management in Thailand. Notifications should be submitted within 60 days from the date of manufacture or importation of any listed hazardous materials that exceed a designated quantity threshold. Once notified, the substances will be added into a new Annex (Annex 5.6) of the current list of hazardous substances. 55

56 Current Management of Existing Chemicals 56

57 Current Management of Existing Chemicals 57

58 New Chemicals (not yet controlled as Type 1-4) Online consultation is usually the first step to evaluate the registration status of the ingredients of the product If any ingredient of a product is not yet regulated, a notification is necessary: Submission of Notification-Dossier (product composition, manufacturing process, Certificate of Free Sale, label, MSDS, toxicity data, use, analytical method, ) Decision about whether substance is hazardous and which of the government agencies will be assigned as responsible 58

59 Current Management of Existing Chemicals 59

60 HS List 5.6: Controlled Substances based on Hazard Properties No. Hazard Properties 1 Explosive 2 Flammable substance 3 Oxidizing agent or Peroxide 4 Toxic Substance 5 Mutagen 6 Corrosive 7. Irritant 8. Carcinogen 9. Toxic substance to reproductive organ 10. Environmentally hazardous substance Hazardous Substance under the condition only substances or mixtures not having responsible agency for production or import. They shall be compiled with criteria and method prescribed by MOI 60

61 Notification to list 5.6 Notification to Department of Industrial Works (DIW) via the online system Once within 60 days from the date of manufacture or import Only required for hazardous substances listed in annex 5.6 Information required: Legal entity Type of activity: production or import; Type of hazardous substances: substance or mixture Trade name and HS code Transport information: UN number, class Composition Type of packaging Manufacturer name and country of origin GHS classification Physico-chemical properties, toxicological, ecotox and disposal information (from SDS) Copy of GHS SDS prepared in Thai or English 61

62 Preliminary Inventory DIW published the Preliminary Inventory on 6 th August 2016 ( technical difficulties (use Chrome-browser, offline from time to time) tml It so far contains only hazardous substances which were notified/ registered to DIW between Non-Hazardous Substances are expected to be included later Language mainly only in Thai Even if chemicals are listed, notification/registration of products is still required 62

63 Online Draft Inventory Search by CAS RN or Trade Name 63

64 Formaldehyde 64

65 Proposed Plan for Additional Management Not too many details available yet Expected implementation from 2017 onwards Biggest change to be expected is implementation of Risk Assessment for SVHC and hazardous substances not included on the inventory. Unclear when and how the Risk Assessment will be implemented 65

66 Proposed New Substance Notification Process Submit Notification Dossier to include product composition, manufacturing process, label, MSDS, toxicity data, use, analytical methods Hazardous status and the assignment of the relevant regulating Ministry to be made by the Authority New substances that are not hazardous or do not meet Substance of Very High Concern criteria will qualify for a simplified risk assessment report. SVHC criteria: Production/import volume >=10 MT/year CMR category 1A/1B PBT/vPvB Substances of equivalent concern or included in international conventions For hazardous substances notification of production/import volume will continue to be required when the volume is >1MT/year. Registration and/or License may also be required depending on hazard 66

67 Proposed Existing Substance Management Requirements for existing hazardous substances will remain (e.g., notification of production/import volume, registration and licenses based on hazard types), but in addition the substances will be screened to determine if further action is warranted SVHC criteria will be used to prioritize substances for screening Substances determined to be SVHC will require a risk assessment report. Deadlines for submission will vary based on tonnage band Joint submissions with cost sharing will be possible as well as use of an Only Representative to coordinate information exchange between the registrant(s) and the authority Assessment may result in a change of the existing hazard type 67

68 SUMMARY Depending on classification, a notification, registration and/or license is necessary Products containing substances with hazardous properties must be notified for listing in list 5.6 Setup of a chemical inventory is ongoing Risk Assessments might be required for some new and existing chemicals (SVHC type chemicals) 68

69 GHS Implementation Worldwide With support from J. Breuer, 69

70 Introduction GHS Globally Harmonized System Goal (United Nations) a single, globally harmonized system to address classification of chemicals, labels, and safety data sheets expand the harmonization of the transport sector (UN Model Regulations for Transport of Dangerous Goods) to the workplace and consumer sectors enhance the protection of human health and the environment during the handling, transport and use of chemicals facilitate trade by harmonized rules and regulations at worldwide level. Purple Book 70

71 GHS Globally Harmonized System History First edition of the GHS adopted in December 2002 and published 2003 Update and revision every two years GHS Rev.1 (2005) GHS Rev.2 (2007) GHS Rev.3 (2009) two new sub-categories for respiratory and skin sensitization GHS Rev.4 (2011) new hazard categories for chemically unstable gases and non-flammable aerosols GHS Rev.5 (2013) GHS Rev.6 (2015) new hazard class for desensitized explosives; new hazard category for pyrophoric gases 71

72 Building Block approach: Hazards are grouped into physical, health and environmental hazards which again are divided into hazard classes and categories. Countries are free to determine which of the building blocks will be applied. However, where a system covers part of the GHS, that coverage should be consistent with UN-GHS! This means that any hazard category which is implemented in a national regulatory system, is implemented with all the corresponding GHS criteria. 72

73 Global Implementation Various Shades of Purple 73

74 Status quo: April 2017 Original world map by GHS implemented GHS in process GHS voluntary GHS not yet started

75 Summary When setting up your global business plan /your plan for global compliance, check: What kind of regulation is existing in my target markets? (new chemicals, existing chemicals, hazardous chemicals? What are the relevant inventories and local data requirements? Which options are available to fill these data-gaps? What does this mean with regards to envisaged timelines? Rules for Classification and labelling (GHS)? Special issues (SVHCs)? Language issues? Do you need external help?

76 Thank you for your attention! For more detailed information / questions please visit us at our booth 76