Recently, ECHA Enforcement Forum agreed that its major enforcement project planned for 2022 (REF-10) will focus on integrated controls of consumer products. The Forum agreed that inspectors will be able to check whether products comply with many different restrictions for hazardous substances under REACH and POPs. Specific types of material such as rubber, plastic or textiles, are subject to the duties under REACH and POPs. In this way each product can be controlled by several REACH or POPs requirements which will broaden the scope of controls and strengthening the protection of EU citizens and the environment. This enforcement project will be prepared in 2021, with inspections conducted in 2022 and the report expected at the end of 2023.

This round of law enforcement mainly checks whether consumer products meet the restriction requirements of the following two types of restricted substances:

1. REACH regulations restricted substances

The Annex XVII Restricted Substance List currently contains 75 substances, among them, the newly listed hazardous substances will also be included in the scope of this sampling, such as:

  • Entry 72-carcinogenic, mutagenic and reprotoxic substances in textiles,
  • Entry 70-the siloxanes D4/D5 in wash-off cosmetic products
  • Entry 66-bisphenol A in thermal paper.

2. Substances controlled by POPs regulations

At present, the POP Regulation ((EU) 2019/1021) Annex I Prohibited Substance List contains a total of 28 Persistent Organic Pollutants (POPs), and the Annex II Restricted Substance List has not yet included any substances. This round of enforcement will conduct random inspections on the compliance of POPs regulations in consumer products, such as:

  • PFOA in water repellent textiles or ski waxes
  • Short chain chlorinated paraffins in soft plastic articles (SCCPs)

The lists of REACH and POP restrictions that will be covered in the project are still under development. Enforcement will not be limited to the substances and restrictions listed in this article.

Enforcers will also check REACH duties for substances in articles requiring that information on substances of very high concern (SVHCs) in products is being communicated in the supply chain.

To promote the integrated enforcement of chemicals legislation, the controls of the project will also allow inspectors to cooperate with authorities responsible for enforcing requirements of the Toy Safety and RoHS directives, which are complementary to REACH and POPs and restrict the presence of certain substances in toys, and electronic and electrical equipment.

In order to ensure the compliance of exported products, it is recommended that companies refer to the full version of the Annex XVII list and SVHCs list of REACH regulations and the list of controlled substances under POP regulations, and take effective compliance measures in a timely manner.

CIRS C&K Testing is a subsidiary company established by CIRS Group to promote the rapid development of the group's testing business. It has grown into a professional, comprehensive, and international independent third-party testing organization. The company advocates the concept of "healthy life" and professionally develops product testing services, involving food and related products, cosmetics, environment, consumer products, industrial products, chemicals and other fields.

At present, CIRS C&K Testing has established branches in Ireland, the United States, South Korea, the United Kingdom, Beijing, Nanjing and other places. CIRS C&K Testing will continue to serve global customers, helping companies to confirm product information, quality and safety, avoid international trade barriers, and enhance brand competitiveness.

CIRS C&K Testing Laboratories established a laboratory management system in accordance with ISO/IEC 17025 and continuing to operate effectively. Many laboratories are equipped with Agilent Gas Chromatography Mass Spectrometer (GC-MS), Shimadzu High Performance Liquid Chromatograph, Ultraviolet/infrared spectrophotometer, Atomic Absorption Spectrometer, Platinum Elmer Inductively Coupled Plasma Emission Spectrometer (ICP), X-ray Energy Dispersive Spectrometer (EDX), Anton Paar Microwave Digestion Apparatus and other advanced testing instruments and equipment. Relying on advanced facilities and entrepreneurial spirit that demanding specialty and strong technical strength, CIRS C&K Testing continues to innovate itself, participates in the drafting of national standards and has a number of laboratory technology patents.

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