On June 1, 2007, the REACH Regulation ("Regulations on Registration, Evaluation, License and Restriction of Chemical Substances") formally came into effect. REACH is a chemical management regulation of the European Union for preventive management of all chemicals entering its market. As we all know, the EU is a major trading partner of China, and the implementation of this regulation will have a profound impact on Chinese companies. In addition to the direct impact on chemical companies, REACH will have an impact on all companies that produce downstream chemical products, including textiles, machinery, toys, furniture, and more. There are more than 1 million products involved. Since June 2008, the implementation of REACH regulations has entered the pre-registration stage. As the registration deadline is approaching step by step, how should Chinese flame retardant companies respond to this large technical trade barrier set up in the history of the EU?
As early as 2007, China Inspection and Quarantine REACH Solution Center got in touch with a number of flame retardant companies and began to formulate REACH response plans for the flame retardant industry. In May of this year, the REACH Solution Center was invited by the Chinese Flame Retardant Society to participate in the annual academic meeting of the flame retardant industry and gave a special report on REACH regulations at the meeting. At the meeting, Dr. Yu Haixia, an expert from the Solution Center, introduced the research results of the center's flame retardant industry's REACH response work to the participating companies in detail, and formally established China's flame retardant industry's response to EU REACH regulations.
At present, nearly 80% of the flame retardants used for plastic modification in China are halogen-containing flame retardants. Among them, polybrominated diphenyl ethers and polybrominated biphenyls are represented. Brominated flame retardants have high efficiency and low dosage, and have great impact on material performance. The impact is small and the price is moderate. The environmentally friendly flame retardants exported by my country are mainly divided into environmentally friendly bromine flame retardants, phosphorus flame retardants, nitrogen flame retardants, inorganic flame retardants and other categories. Based on the classification of products under REACH regulations, the flame retardant industry in my country can refer to the following steps in the process of responding to regulations:
First of all, you should clarify the classification of your products in REACH regulations. According to the research of the Solution Center, there are many types of flame retardants, and the products involve substances, preparations, and polymers. Enterprises need to accurately locate their products. If it is a preparation, it needs to determine the substance content and tonnage; if If it is a polymer, it is necessary to analyze and determine the monomer whose content is greater than 2% and the annual export volume is greater than one ton as a registered substance.
In the second step, the company needs to check the EC number to confirm whether the required registered substance is a phased substance. If it is a phased substance, it needs to complete the pre-registration between June 1 and December 1 this year; if it is a new substance, it needs to The new substance registration will be started immediately after June 1.
In the third step, the company needs to confirm the tonnage information of the product to be pre-registered to determine the buffer period it has obtained.
In the fourth step, the company needs to choose the appropriate registration method to complete the pre-registration/registration according to its own circumstances. If the registered flame retardant is a brominated flame retardant, it may produce toxic and hazardous substances after burning. Therefore, it may be Restricted or authorized under REACH regulations.
Case study of flame retardant products:
Taking brominated epoxy resin as an example, a company exports 300 tons of flame retardant brominated epoxy resin to the EU every year. The registration steps are as follows:
1) Determine the material properties: Brominated epoxy resin is a polymer.
2) Determine the monomers: epichlorohydrin, tetrabromobisphenol A (mixing ratio 8)
3) Clarify the registered substances: two monomers with a mass fraction greater than 2% and a tonnage greater than one ton must be registered.
4) Determine whether to phase the substance:
Epichlorohydrin CAS NO: 106-89-8; EC NO: 203-439-8
Tetrabromobisphenol A CAS NO: 79-94-7; EC NO: 201-236-9
5) Step 5: Conclusion
The flame retardant brominated epoxy resin needs to be registered as its monomer epichlorohydrin and tetrabromobisphenol A. The two monomers are both phased substances, and pre-registration is required between June 1, 2008 and December 1, 2008. According to its tonnage in the polymer, it enjoys a registration buffer period of 2-10 years and completes the registration before the corresponding registration deadline.
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