By Ancuta Rusu
The Forum for Exchange of Information on Enforcement (Forum) announced a new project, REACH-EN-FORCE-6 (REF-6), which will coordinate enforcement of classification and labelling of mixtures throughout the Member States.
The Forum is a body of ECHA with members appointed by the Member States. They coordinate the network of enforcement authorities in the different Member States through REACH-EN-FORCE projects. The 5 previous projects include:
* REF-1 on registration,
* REF-2 on supply chain duties,
* REF-3 on registration (continuing REF-1 but with a different emphasis and targets),
* REF-4 on restrictions,
* REF-5 on extended SDSs.
The recently announced REF-6 on classification and labelling of mixtures was borne of the two-year transitional period for mixtures that were classified, labelled and packaged under the DPD legislation and which were placed on the market before June 2015. Per ECHA, “Such mixtures will only have to be labelled and packaged in accordance with CLP by 1 June 2017.”
REF-6 will coordinate enforcement on not only the classification and labelling of hazardous chemicals, but also on the related sections in Safety Data Sheets that affect the labelling: Sections 2, 3, 9, 11 and 12. Additional modules for REF-6 are foreseen and these include: notifications to the C&L inventory, application of C&L exemptions and liquid laundry detergent cap packaging rules.
A project manual for REF-6 will be prepared in 2017 and inspections will take place in 2018. The inspectors will be provided with an inspection questionnaire translated into various Member State languages.
Some inspections have already started and are targeting whether internet sales are compliant, meaning do the sellers provide the required information when selling hazardous chemicals on-line, as previous REF reports have shown that there is a considerable number of non-compliant companies that do not fully observe REACH or CLP obligations.
Publication of the report for REF-6 is expected near the end of 2019.
2017 is looking like a busy year for the Forum with another pilot project focused on substances of very high concern (SVHCs) in articles as well as a project focusing on PIC obligations where inspectors will check (commencing in 2018) the duties related to export notification.
For additional information about REF-6 and upcoming projects, please refer to the ECHA website.
ECHA, “Forum launches major project on classification and labelling of mixtures,” 11 November 2016: https://echa.europa.eu/-/forum-launches-major-project-on-labelling-of-mixtures
ECHA Newsletter, “Top tips for the CLP 2015 deadline”: https://newsletter.echa.europa.eu/home/-/newsletter/entry/6_14_top-tips-for-the-clp-2015-deadline