In case of import, UFI can be used in the communication with a non-EU supplier. The following way can be considered to work around possible communication problems (e.g. if the non EU supplier intends to protect the confidentiality of the mixture information).
The non–EU supplier has a legal entity based in the EU (or a contractual agreement with an EU-based legal entity), which creates a UFI and makes a submission voluntarily 33 to the Member States where the EU importer intends to place the mixture on the market. The non-EU supplier informs their customer (the EU-importer, directly or via the EU-based legal entity) about this UFI and confirms that the submission is done. Subsequently, the EU importer, who is the actual duty holder, makes their own submission with a reference to this UFI in relation to the compositional information. The importer could therefore make a submission for a mixture containing 100% of the MiM supplied by the non-EU supplier. This option could be useful also when the EU importer uses the mixture to formulate another mixture, and the non-EU supplier wants to protect the confidentiality of the information on the mixture they supply to the EU importer. The obligation to place UFI on the label lies with the EU importer. It is possible for the non-EU supplier to already label their product with the correct UFI before supplying it to the EU importer.
The EU importer and non-EU supplier are strongly recommended to enter into a contractual agreement to cover the details of the submission approach chosen. It should be kept in mind that the EU importer remains in any case the duty holder and therefore responsible in front of the enforcement authorities. Furthermore, the EU importer remains responsible for the fulfilment of other obligations under CLP (e.g. classification of the mixture).
We are delighted to announce that Sustainability Support Services (SSS) Europe AB has recently changed its registered name to Global Product Compliance (GPC)Europe AB as part of the recent acquisition by the Global Regulatory Compliance Holding.
The new name GPC Europe AB will be officially effective from 1st July 2020. Wherein,
No change is applicable to the
The changes that would be affected are:
Read more here
The additions include three substances that are toxic to reproduction and one endocrine disruptor. The Candidate List of substances of very high concern (SVHCs) now contains 209 substances that may have serious effects on people or the environment.
Helsinki, 25 June 2020 – The endocrine-disrupting substance is used in consumer products, such as cosmetics. The three others are used in industrial processes to produce polymers, coating products and plastics, respectively.
Companies are urged to check their legal obligations relating to the safe use of their substance. From January 2021, companies will also have to notify products containing SVHCs to ECHA’s upcoming SCIP database on substances of concern in articles and products. The database aims to ensure transparent information on articles containing hazardous chemicals throughout their whole lifecycle.
ECHA’s Director of Hazard Assessment says: “Chemicals on the Candidate List are among the most regulated in the EU, and our aim is to gradually phase them out. In the meanwhile, companies need to ensure their safe use and be transparent towards consumers who have the right to know where these chemicals are used. Substituting them with safer alternatives can boost innovation and create a more sustainable circular economy.”
Substances added to the Candidate List for authorisation on 25 June 2020:
|#||Substance name||EC number||CAS number||Reason for inclusion||Examples of use(s)|
Toxic for reproduction
|In formulations and as a monomer in the production of polymers|
Toxic for reproduction
|As a catalyst in the production of coating products|
Toxic for reproduction
|As a catalyst and as an additive in the production of plastics|
|202-318-7||94-26-8||Endocrine disrupting properties - human health
(Article 57(f) – human health)
|Cosmetics, personal care products and pharmaceuticals|
ECHA’s Member State Committee was involved in the decision to include butyl 4-hydroxybenzoate and dibutylbis(pentane-2,4-dionato-O,O')tin to the list.
The Candidate List includes substances of very high concern that may have serious effects on our health or environment. These may be placed on the Authorisation List in the future, which means that industry would need to apply for permission to continue using them.
Companies may have legal obligations when their substance is included in the Candidate List - either on its own, in mixtures or in articles. Any supplier of articles containing a Candidate List substance above a concentration of 0.1 % weight by weight has to give sufficient information to their customers and consumers to allow safe use. As of January 2021, companies will also need to notify ECHA’s SCIP database if their articles contain Candidate List substances.
Importers and producers of articles containing a Candidate List substance also have six months from the date of its inclusion in the list (25 June 2020) to notify ECHA.
More information on these obligations and related tools are available on ECHA’s website.
Candidate List substances: overview of hazardous properties
Of the 209 substances now on the Candidate List of SVHCs for authorisation, a large majority are carcinogenic, mutagenic or toxic to reproduction. Many of them have several hazardous properties.