Implementation of REACH: The national REACH-CLP Helpdesk in Germany Andreas Fleischer Federal Office for Chemicals TAIEX Workshop on REACH, Belgrade 12 November 2009

Belgrade, Outline The Federal Office for Chemicals Helpdesk activities: Aims, challenges and co-operation Pro-active Information services Information on demand Statistics, frequent topics

Belgrade, REACH and BAuA The Federal Office for Chemicals is: responsible for implementation of statutory regulations to protect man and the environment from hazardous substances. contact point for the chemicals industry; receives relevant chemical data, which are examined in co-operation with different assessment authorities (environmental, consumer and worker protection).  REACH procedures: e.g. dossier preparation for harmonized Classification and Labelling, SVHC identification, substance evaluation  REACH and CLP Helpdesk  Authorisation procedure for biocidal products  Cooperation with enforcement authorities  PIC/POP  Ozone depleting substances (ODPs - CFCs - chlorofluorocarbons)

Belgrade, BMU  Ministry in Charge BAUA FB5  Federal Office for Chemicals BAUA FB4  Hazardous Substances and Occupational Safety BfR  Federal Institute for Risk Assessment UBA  Federal Environmental Agency BAM  Federal Institute for Materials Research and Testing Federal states  Enforcement authorities Helpdesk – Federal level

Belgrade, German helpdesk activities Member State task / obligation: To establish a national REACH-helpdesk (REACH Title XIII Competent Authorities, Article 124 Other responsibilities) To establish a national CLP-helpdesk (Article 44, CLP-Regulation (EC) Nr. 1272/2008 Member State task / obligation: To establish a national REACH-helpdesk (REACH Title XIII Competent Authorities, Article 124 Other responsibilities) To establish a national CLP-helpdesk (Article 44, CLP-Regulation (EC) Nr. 1272/2008 Aim To provide advice to companies on their responsibilities and obligations under REACH (in particular in relation to registration) and CLP Aim To provide advice to companies on their responsibilities and obligations under REACH (in particular in relation to registration) and CLP

Belgrade, Challenges for Member States in REACH implementation  Availability of resources –To ensure efficient implementation of REACH processes –To ensure appropriate level of Helpdesk support for industry  Awareness raising and training –To prompt companies that still are sleeping  Efficient enforcement –To ensure fair competition within internal market –To ensure that higher level of protection for health and environment is achieved

Belgrade, Aims of a REACH-helpdesk Access via all communication pathways Fast, qualified and consistent answers Consistency throughout the EU Help for self-help

Belgrade, Co-operation - Regional level REACH Helpdesk (BAuA) Regional Helpdesks e.g. REACHnet (NRW), REACH Help (BW); etc. Companies (Manufacturer, DU, Importers etc.) Industrial associations Inspectorates ECHA - Helsinki

Belgrade, Services offered: pro-active on demand - Brochures: REACH-Info - Translations - Internetportal: - Seminars / Workshops - Other awarness raising activities (e.g. press releases, presence at trade fairs, …) - Presentations - Expert meetings/consultations - Answers to direct inquiries Services offered by the REACH-CLP Helpdesk Taks: Support and give advice to manufacturers, importers, downstream users, distributors and other interested parties with the compliance of their obligations under REACH and CLP

Belgrade, Internet portal

Belgrade, News - Important deadlines - Topics A-Z - Decision Tree - Legal texts and guidance - FAQ - Glossary - Events - Brochures

Belgrade,

New 2009:  REACH-Info 6 Articles: Obligations for Producers, Importers and Distributors REACH-CLP Helpdesk – Information material REACH-Info: Series of brochures Planned 2010:  REACH-Info 7 Recycling

Belgrade, Workshops Organization of BAuA-REACH events (approx. 250 participants): REACH: New trends! REACH, Recycling, Waste – what should be done? SIEF, Consortia and joint submission GHS and its implementation in the EU Registration dossier Exposure assessment Information requirments

Belgrade, REACH Helpdesk – Answering Questions Manufacturer, Importer, Downstream User Infocenter at BAuA Dialogue Back-Office BAuA Division 5 Question Answer Knowledge base/ Publishing FAQs Expert UBA, BfR, FB4, BAM, EU-Network

Belgrade, disclaimer tailored made answer logo Address contact & phone Reference number

Belgrade, Statistics Answers within 1 – 6 weeks depending on complexity of question (e.g. concerning UVCB*; example: enzymes) Several “difficult” questions identified, which are fed into the EU helpdesk network (e.g. concerning ‘only representative’) Questions were asked by IHKs, SMEs, REACH- consultants, big companies, and by Asiatic stakeholders * Substances of unknown or variable composition, complex reaction products or biological materials

Belgrade, REACH-CLP Helpdesk Statistics Inquiries to the REACH-CLP Helpdesk End of preregistration periodEntering into force of REACHStart of preregistration period

Belgrade, REACH-CLP Helpdesk Statistics: Topics Inquiries 2008 by topic Inquiries 2009 by topic Top-Issues 2008 Registration obligations52 % Exemptions15 % Downstream users12 % Preregistration 9 % Top-Issues 2009 Registration29 % Preregistration, SIEF11 % Supply chain 9 % Exemptions 9 %

Belgrade, Information Centre – Front office

Belgrade, Expert meetings / consultations About 40 expert meetings in 2008/2009 with industry took place on: steel works / smelters metals glass how to test / register difficult substances cosmetics, cleansing products paper industry nano-materials etc.

Belgrade, Presentations Helpdesk staff, giving talks at chambers of industry and commerce, e.g. IHKs invited BAuA-speakers for specific REACH-events 2008/2009: approx. 50 events Topics: Recycling Substance Identity Preregistration Introduction to REACH Polymers

Belgrade, Scope - Resources  Scope of national helpdesk at the BAuA: provides advice on technical issues, even of complex scientific nature however: German federal helpdesk not responsible for registration obligations of industry!  Resources involved at BAuA – notification division: currently for helpdesk activities approx. 10 staff involved (however not fulltime). however: more resources needed for increased support demands by SMEs and support on CLP in future

Belgrade, Frequent Questions regarding Textiles  What is a substance, intended to be released (Jeans loosing colours???)  Borderline cases, fibres: substance vs. article  Restrictions of substances in textiles  Information obligations (Art. 7, Art. 33)  SVHC, e.g. Flame retardants in textiles  Communication in the supply chain on SVHC

Belgrade, Finally: How to contact the German Helpdesk Phone: – Fax (Monday-Friday 8.00 – 16:30 h) Thank you for your attention!