ITMA 2015 Textile Colourant & Chemical Leaders Forum. Updates on REACH Regulation. Dr Maurizio Colombo, REACH and CPL Coordinator, Federchimica

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1 ITMA 2015 Textile Colourant & Chemical Leaders Forum Updates on REACH Regulation Dr Maurizio Colombo, REACH and CPL Coordinator, Federchimica Milano, 14 th November 2015

2 Federchimica Organisation More than 1,300 Member Companies ~ 90,000 Employees General Management Department 5 Departments Legal Affair Management Image & Communication Bruxelles Delegation 17 Sector Associations 41 Product Groups 90 experts supporting Companies

3 Federchimica s representatives in Europe AGROFARMA ECPA ASCHIMFARMA EFCG CERAMICOLOR EUROCOLOUR CEFIC FEDERCHIMICA 28 Associations 21 Board Members AIA FEA AISA IFAH-EUROPE AISPEC AMAFE CESIO EFFA EFfCI ELC EUROPALUB FEPA IFRA IOFI UEIL ASSOBASE APPE ESA EUROCHLOR ASSOBIOTEC EUROPABIO ASSOCASA AISE ASSOFERTILIZZANTI FERTILIZER EUROPE ASSOGASLIQUIDI AEGPL ASSOGASTECNICI EIGA PLASTICSEUROPE ITALIA PLASTICSEUROPE AVISA CEPE FEICA Chemicals Companies active in Textile Area are AISPEC members ASSOSALUTE AESGP ASSOFIBRE CIRFS ITALIA CIRFS COSMETICA ITALIA COLIPA

4 Partecipation as the added value Economic Analysis Internationalisation Communication Image FISCAL COMMETTEE COMMUNICATION & IMAGE COMMETTEE More than 60 Committees, GdL e Task Forces for participants Internal Relations PERMANENT LABOUR COMMITTEE LEGAL AFFAIR COMMITTEE SAFE, HEALTH AND ENVIRONMENT COMMITTEE Technical & Scientific Affairs ENERGY COMMITTEE WORKPLACE HEALTH COMMITTEE LOGISTIC COMMITTEE R&S AND INNOVATION COMMITTEE PRODUCT SAFETY COMMITTEE

5 SICUREZZA PRODOTTI (PRODUCT SAFETY) Items Association Structures Products & Projects Chemical Weapons, Dual Use, Drugs & Explosive Precursors. REACH, Food Contact Materials, Drinking Water Contact Materials, Scientific- Issues, G.E.R.. COMITATO SICUREZZA PRODOTTI (CoSP) Steering Commitee G.d.L. Armi Chimiche e Dual Use G.d.L. Biocidi G.d.L. Materiali a Contatto con Alimenti G.d.L. GER G.d.L. REACH e CLP T.F. to organize case by case T.F Annual Conference Sicurezza Prodotti: REACH Meetings ECHA & Industries Registration Support to Industry (CentroReach) Guidelines CLP/GHS, Biocides,, Chemical Mixture, GHS in the World More than 100 Experts (Association and Companies) Training Activities Monthy Reports...

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7 REACH: but Relevant impact on Italian industrial districts, including textile industry. SMEs have not sufficient resources Euro/Human R. In textile area, many SMEs supply chain decided to stop activity or a strong reduction of the business Reach pro Global Market? SIEF/Consortia activity could pose problems for CBI and not clear management anti trust? REACH should be based on risk evaluation, but it is intended as hazard-base legislation. SVHC is a good example IN/OUT Short time for first registration deadline, guidelines not ready or modified during he last years Learning by doing? Huge amount of documents to consider, different interpretations also for the enforcerment EU simplification of regulations program? The scope of the Regulation is to have positive impact on HSE and R&D but..

8 REACH in Italy: registrations and costs ITALIA Substances At December Fees 46 Estimation on REACH costs without the cost for internal human resources Additional Costs 15 >> 55 Dossiers TOTAL 77 >> 270 Mil

9 REACH in Italy: improvments in R&D? Proposta di Regolamento REACH, 2003 Regolamento REACH 2006 Fonte: stima Federchimica su Community Innovation Survey, Eurostat Fonte: Istat In Italy not relevant changes, but reduction compared with 80s.

10 Workplace Accident number for 1,000,000 working hours PRIMA SCADENZA REACH REACH in Italy: better HSE? Federchimica Responsible Care data Air Emissions (production rate constant) PRIMA SCADENZA REACH NOx Polveri Water Emissions (production rate constant) REACH does not affect the HSE indexes PRIMA SCADENZA REACH COD N

11 REACH 1. No Polymer registrations required under REACH; low tonnage requirements (1-10 tonnes) unchanged. 2. CSR improvements should not result in doing all CSRs over again. Help with dossier quality 3. SVHC 2020 roadmap with decent possibility for industry to contribute early enough, including on the socioeconomic impact. RMO is working in part; simplification currently underway. 4. CORAP list will be continuously updated Status News Commission advised us that there will be no changes recommended before Efforts ongoing. 3. During the 6 th recommendation for prioritisation in the authorisation list the input from industry has directly affected the selection of substances. 4. Commission is committed to «simplify» the Authorisation process and is taking industry s input into account. AND REMEMBER: K-REACH on Korea, REACH like legislation in Taiwan, China, Turkey

12 Other 2015 News CLP 1. Poison Centres Information: workable approach and harmonised input all over EU. 2. Harmonised classification: promote joint classification efforts by industry to become more effective and visible. Assist members regarding the Mixtures deadline with workshops. Status 1. Latest Commission proposal meets several of industry s requirements for harmonisation. 2. In progress (pilot stated with ECHA) and good progress is being reported. 3. Workshops completed on Mixtures and deadline passed smoothly with the enforcement authorities being learn ant on companies during the transition period.

13 And also And also Endocrine Disruptors Nano materials Inclusion of risk management into the final EU policy option adopted (via criteria, safe thresholds and the revised Community Strategy). Minimise the specific regulatory/testing requirements needed for nanomaterials (via nano incorporation in the REACH Annexes, no EU inventory, more workable EU definition). Nanotechnology like any other. Status Potency included one of the options featuring Impact Assessment (results of IA expected Q1/Q2 2016). 1. Progress being made on the Impact Assessment on the inventories (no EU inventory) 2. Definition, 3 rd JRC report published, it includes different options for the modification of the definition 3. REACH Annex changes delayed by the Commission, expecting impact assessment

14 And also hot topics 2018 REACH deadline for t/y, start activity, check supported substances SDS and esds Relevant point for Enforcement 4, training in supply chain Formaldehyde New classification H350, residual in natural and synthetic chemical processes Tex.Certifications Increasing number, increasing level of requests. Less reliability

15 Conclusion REACH is a very demanding system for any business either large or small, yet right from the start one of the more serious concerns was whether and how SMEs will survive with the Regulation. SVHC, CORAP and other lists are considered definitely BLACK LISTS (no risk-based approach, no differences for residual Q ) The chemistry seems to be a misplaced element in Europe, and the regulations seems suggest this thesis, but the "bad" chemistry can be still exist in the imported articles where the regulation is weak. Other than REACH, the European Companies have a lot of other regulations which are and will influenced by REACH (environmental emissions, safety at work, product regulations, transport) We need to have a continuous contact with Authorities at national and European level, to obtain a "better regulation", to follow the enforcement activity, and to help our Industry to maintain an high level of human and environmental protection and also support our competitivity.