Do you trade chemicals globally? Here’s why you need to continually monitor regulatory lists

Regulatory horizon scanning is essential for a sustainable business, product portfolio management and compliance with global chemical regulations. However, monitoring the breadth of regulations can be time-consuming and problematic. That is why Ricardo launched its horizon scanning tool, which performs a substance inventory check and identifies whether your substances appear on any global regulatory lists, helping you quickly determine the most recent status of your substances.

The appearance or movement of your chemical substances within global regulatory lists requires organisations to take actions such as phasing out a certain substance from your product range, altering its concentration, or introducing specific workers' safety procedures. For example, the European Chemicals Agency (ECHA) updates its lists, created under the Registration, Evaluation and Authorisation of Chemicals (REACH) Regulation, twice every year, often resulting in the movement of substances between lists. Each stage under REACH carries its own regulatory implications and mitigation steps.

Below are three key updates that makes it imperative for you to regularly monitor the regulatory lists:

1. Chemicals Strategy for Sustainability (CSS)

The European Commission’s CSS consists of a series of actions and strategies which specifies how chemicals will be regulated in the EU. Although new strategies have been introduced, CSS also includes existing strategies that have been updated to provide a greater level of regulation on more substances, which means updates to ECHA lists. If you trade in the EU, it is very likely that you and your customers will be affected by CSS, as well-known regulations such as REACH and the Classification, Labelling and Packaging (CLP) will be changing. 

2. Safety data sheet (SDS) updates

If your mixture contains any of the substances of very high concern (SVHC) present on the REACH Candidate List in more than 1% weight by weight (w/w) (or 0.1% w/w on request, including if the overall mixture is non-hazardous), you need to update your SDS.
 
Additionally, ECHA regularly updates Adaptation to Technical Progress (ATP) to the CLP Regulation. Each update has potential to trigger a number of changes to product SDS and poison centre notifications.
 
If you need any help with SDS authoring to maintain compliance, get in touch with us or visit our dedicated SDS page on our website for more information.

3. Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database

Companies that are manufacturing or importing products in the EU have a legal obligation to ensure that none of their mixtures, articles or substances contain items included on the REACH Candidate List of SVHCs. Any manufacturers, importers, or suppliers of articles with Candidate List substances that exceed a concentration of 0.1% weight by weight (w/w) must submit notifications to the SCIP database within six months from inclusion of the SVHC on to the List. For that reason, it is paramount to regularly monitor the Candidate List. More information about how Ricardo can help with SCIP notifications can be found on our SCIP website page.
 
It is paramount for manufacturers, distributors, suppliers and end users to be aware of and regularly monitor the status of their substances if part of any of these lists. The sooner you are aware of your obligations, the more time you’ll have to implement the appropriate changes. 

How Ricardo can help

Our horizon scanning tool performs a substance inventory check and identifies whether your substances appear on any global regulatory lists. It provides the results in a clear, easy-to-read report, where you can quickly determine the most recent status of your substances.

The tool is available in bronze, silver and gold packages offering varying levels of support to cater to individual needs. Bespoke reports are also available, where chemical regulations and databases are included to meet your specific needs. The tool can be purchased as a once-off, or you can subscribe to it for 3 or 5 years, so you can receive the status of your substances as soon as the information is made available.  

Download our sample horizon scanning compliance report for the Silver level.

Our experts regularly monitor these lists and update our in-house database ensuring the reports issued contain the most recent developments. As part of the subscription, reports are issued twice per year in line with ECHA’s release of updated REACH lists, which enables you to act as soon as the information is made available. This gives you more time to properly implement actions such as phasing out a certain substance from your product range. This way, our horizon scanning tool will determine what your obligations are, allowing you to make strategic decisions sooner helping you reduce time, expense and resource investment required to understand the complex regulatory requirements and guarding you against enforcement actions. 

Read more about our horizon scanning solution >