REACH in China Experience with preparing for REACH in China Liu Bin CCCMC Europe Representative Office in Europe China Chamber of Commerce of Metals, Minerals & Chemicals Importers & Exporters
REACH s Impacts on Chinese Industries Status Quo in China CCCMC Experience
Part 1 REACH s Impacts on Chinese Industries
China s Trade Partners The expanded EU has become China s largest trade partner. Source: Accumulated Import and Export Value, Jan-July, 2008, Chinese customs statistics
EU and China Chemicals Trade 2006: 10.27Billion USD, +15.6% 2007: 12.38Billion USD, +27.9% 2008.1 7: 9.27 Billion USD, +34.4% EU China 2006: 10.03 Billon USD, +22.0% 2007: 11.50 Billion USD, +37.1% 2008.1 7: 8.86 Billion USD, +34.5% There is great potential in the growth of Sino-European chemicals trade.
Quantity of Chinese Commodities Categories Requiring Registration In 2007 chemical commodities exported from China to Europe had 1,007 tariff codes 429 weighing more than 1,000 tons 297 weighing more than 100~1,000 tons 147 weighing 10~100 tons 134 weighing1~10 tons We estimate that more than 2000 substances manufactured in China will have to be registered.
Challenge and Opportunity Challenge: Negative effects on trade relationship (Imp & Exp) Challenge on the producing process management Cost of money and time Understanding of Regulation and Guidance is not easy Opportunity: Upgrade of low end chemical production Elimination of unqualified companies Reference for chemical safety management system
Part 2 Status Quo in China
Big Picture
Major Difficulties of SMEs in China Cost: High and Uncertain Expert: Lack of skilled professionals Partnership: Difficulties in choosing partners Data: Difficulties in data management
High and Uncertain Costs High Regulation Fees/charges (COMMISSION REGULATION (EC) No 340/2008) Even Higher costs for SVHC It is difficult to estimate experimental expenses of single substance
Difficulties in Data Management For manufactures of some enterprises, it is particularly difficult to test the content of substances in articles Many enterprises do not have sufficient data and information In China there are few qualified institution to undertake chemical experiments following the REACH requirement
Difficulties in Choosing Partners The registration agent can be overseas importers importers may not want to do and even if, there are risks of losing core trade secrets and trading channels The so called Chinese ORs are too many to choose the most competent one Since EU data about downstream users and importers are all within the knowledge of the OR, choosing a competent exclusive agent can reduce the risks Overseas OR companies : communication barriers/culture differences
Part 3 CCCMC EXPERIENCE
CCCMC Brief Introduction CCCMC was set up on September 1, 1988 in Beijing. Has more than 4,200 members. Members can substantially represent the overall strength of Chinese metal, mineral and chemical industry. Imports and exports amounts of CCCMC members occupy nearly 30% in the industry; each year around 250 Members will be ranked among top 500 national enterprises in aspect of import and export.
Professional Service Team 7 years of experience of study REACH since the White Paper long time experiences in industrial coordination, communication channels with different international/european industrial associations.
Public Relation and Lobbying By lobbying related Chinese government department, we have gain full support from Ministry of Commerce on REACH matter. Close relation with Chinese embassies in Belgium and Finland. Relation with ECHA, EU commission and several European industrial associations.
Cooperation and Partnership We have made and are making partnership with selected European organizations. CCCMC Europe is member of Helsinki Reach Centre. Partnership with REACHLaw,B lands, KECE etc.
Awareness Raising and Training We have held more than 20 seminars/trainings (most of them are free) cooperating with MOFCOM and provincial governments. More than 5000 personnel from more than 2000 companies attended those trainings.
Consulting Chinese helpdesk: www.reach helpdesk.cn We have translated some guidance into Chinese. Every day we receive phone calls, emails and faxes asking various questions about REACH.
Other services Substance evaluation Dossier Preparation Risk assessment Recommend suitable ORs for companies SIEF Management Data Share Only Representative : Representing more than 200 companies.
Establishment of CCCMC Europe To Create and strengthen communications with partners in Europe; To provide Chinese enterprises services including REACH complementation and trade promotion; To Facilitate European industries and companies to understand Chinese industry and enter Chinese market.
Our Difficulties OR industry has no organized lobbying group Insurance: cost and choices Downstream Users information collection. Limited Human resources
Plan and Suggestion More cooperation with counterparts from other Non EU countries Strengthen communication with European industrial associations to attend more consortia Ascertain cooperation with European Service providers in detail. Wish to collaborate with Indian friend!
Conclusion 1. REACH poses serious challenge to EU China trade relation, but we take that also as an opportunity. 2. Great efforts have been made in China. 3. Emerging OR market in China may bring opportunity and problem. 4. Closer communication between foreign manufacturers and EU down stream user are important for the benefits of both sides. 5. Cooperation of Non EU countries benefit all.
Thank you! www.cccmc.org.cn