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January 2020 SPRAY 17
whether they are used in compliance with the conditions
set in the authorization decision.
The enforcement project will be prepared in 2020,
inspections will be conducted in 2021 and the report is
expected to be published at the end of 2022.
The Forum also started preparing the pilot project on
substances recovered from waste, especially related to the
exemption from the registration duty, but may also address
other duties related to chemicals in waste. The scope and
timelines of this project will be refined in early 2020.
The Enforcement Forum has also started to work on the
first update of its compendium of analytical methods recommended
for enforcement of REACH restrictions. Third
party input for this update cycle is welcome.
SDS
In its annual open session, the ECHA Enforcement Forum
also concluded its joint action with stakeholders on the
quality of safety data sheets (SDS); inspectors identified
frequent non-compliances with SDS and discussed with
stakeholders how they could be addressed. The Forum
offered to provide its feedback on standard phrases for
the SDS that industry uses when generating SDS. ECHA’s
accredited stakeholders have committed to a number of
actions such as identifying examples of best practice SDS,
training companies on the quality of SDS
or developing sector use maps and promoting their use.
As part of the open session, 12 stakeholders and the
Forum discussed a number of other issues ranging from industry
initiatives for updating registration dossiers, enforcement
of dossier compliance and animal testing.
SVHC pilot project
An ECHA Enforcement Forum pilot enforcement project has
found that 12% of inspected products contain substances of
very high concern (SVHC). The majority (88%) of suppliers of
these products are failing to communicate sufficient information
to their customers about SVHC in products they supply.
The results of the pilot project show that companies need
to improve their knowledge on the products they supply to
their customers and to better communicate information so
that products containing substances of very high concern
can be used safely.
In this project, 405 companies across 15 countries were
inspected and 682 articles were checked. Eighty-four (12%)
of the 682 articles were found to contain substances listed
as being of high concern to human health or the environment
(Candidate List substances) in concentrations above
0.1% weight by weight. The products checked by inspectors
were selected especially as they were highly likely to contain
targeted Candidate List substances.
“While nearly 90% of the products do not contain substances
of very high concern above 0.1%, the report clearly
shows a failure of communication in the supply chain,” said
Erwin Annys, Head of ECHA’s Support & Enforcement Unit.
“Improvement is needed if we want to make REACH
work in all aspects, contribute to the objectives of the
Circular Economy and to have a good database as required
under the Waste Framework Directive,” he continued.
The ECHA Secretariat & Enforcement Forum will further
analyze the results from the project and consider further actions
that could improve the situation. SPRAY