How Do Chinese Enterprises Look at REACH?

The new European REACH (Registration, Evaluation, Authorization
of Chemicals) regulation has come into force. As soon as the
REACH white paper was issued, Chinese enterprises started to
research the possible impacts of REACH and prepare to cope with
them. How then do these Chinese enterprises look at REACH?
Following are views of some Chinese enterprises exporting
chemical products to the European Union.

Hangzhou Hongyan Pigment Chemical Company Limited:
The company produces only pigments. Its exports to the European
Union account for around 15% of its total sales volume. The work
of coping with REACH is just starting. The company has collected
materials related to REACH but actual preparations have not yet
begun. It is hoped that they can get matters related to
registration ready in collaboration with other companies.

Yantai Wanhua Polyurethanes Company Limited:
Their competitors are basically located in foreign countries.
REACH is therefore an unfavorable factor. Exports to the
European Union market account for a very large proportion of its
total sales. The company therefore pays great attention to the
work of coping with REACH. Preparations for pre-registration
have already started. Simple data about physical and chemical
properties of products are already available. Besides, the
company is contacting foreign users to collect relatively
complete data about exposed situations. The firm will closely
watch the issuance of detailed regulations. One thing is however
certain - no matter how high the registration fee is, the company
will not give up their share in European Union market.

Juhua Group
Products the company exports to the European Union market do not
have many varieties and great amounts. The European Union market
is, however, also very important to Juhua Group. The work of
coping with REACH is therefore still necessary. However the
company feels at a loss as to how it should start. What it is
doing today is making a list of products it exports to the
European Union and organizing relevant persons to read laws and
regulations and REACH training materials.

Shanghai Dyestuffs Company Limited
This company exports as many as 50-60 varieties of products to
the European Union. Technical departments are classifying these
products and conducting economic analysis to determine which
products should be registered and which should not. Downstream
clients are basically textile and dyestuff & chemical
enterprises. They have requested the company to provide them
with safety technical codes. The problem, however, is that China
has safety technical codes for textiles but no safety technical
codes for dyestuffs. Another problem is that China has no labs
that can provide toxicological tests of dyestuffs. As a result
we have no way to prepare such data. Still another problem is
which of the blends should be registered and what the specific
scope is. We need specific guidance in this respect.


Zhang Jie, expert from China Dyestuff Industry Association
To cope with REACH, chemical enterprises should build up their
own strength.

Some contents and implementation methods in REACH are in
violation of relevant WTO provisions or not in conformity with
international practices. Exporters or exported products in
China can suffer serious impacts. In light of the timetable for
the implementation of REACH, however, Chinese enterprises
should accelerate their development and build up their strength.
   First of all, we should highlight innovation. As requirements
on environmental protection and human health are getting higher
and higher in the international market, Chinese enterprises must
make great efforts in the development of various
environment-friendly chemical substances to meet the strict
requirements with regard to toxicity, mutagenicity,
carcinogenicity, heredity, nervous immunity and allergy. It is
also the content of risk evaluation in REACH. In this way not
only will the international competitiveness of products be
enhanced, but the domestic environment will benefit. Secondly,
we should highlight high and new technology. There are quite a
lot of high and new technologies in the chemical sector today
such as atomic economic reactions, biochemical technologies and
new commercial-scale catalytic technologies. Chinese
enterprises should use high and new technologies and
international standards to organize production and constantly
upgrade the overall technical level to ensure the overall safety
and ecological quality of chemicals they produce. Besides,
Chinese enterprises should also highlight optimization and
accelerate readjustment to product portfolio. Chemical
enterprises should eliminate products that cause serious
pollution and products at low technical level, and strictly
control the further construction of production units with low
technology.


Qian Hongyuan, CNCIC Chief Engineer  
It is imperative to get prepared for pre-registration.

REACH has come into force. What is the most important step next?
It is requested that pre-registration should be completed within
12-18 months after REACH comes into force. That is to say, the
time limit defined is from June 1st 2007 to November 30th 2008.
Manufacturers and importers can have a transition period after
pre-registration. They can make preparations for registration
while doing further manufacturing or import. In addition,
pre-registration can facilitate information sharing, avoid
repetitive research especially in testing effects on
vertebrates and therefore reduce cost. Without pre-registration,
these benefits could not be offered.
   Faced with the implementation of REACH, it is not just
enterprises that have started to act. Chen Huiming, Director of
the Chemicals Safety Research Office, the Chinese Academy of
Inspection and Quarantine advises: After REACH comes into force,
the Chinese Government, enterprises and relevant intermediary
agencies should take action and provide policies, messages,
inspections and intermediate consulting services to help
Chinese chemical and chemical-related enterprises to maintain
their status in the European Union market.
   Management departments of the Chinese Government should
undertake work in the following four aspects. China should
establish centralized laws and regulations on the management of
chemicals and promote effective reform to testing labs in
different departments. China urgently needs to conduct reform
of physical and chemical testing labs of entry/exit inspection
and quarantine systems and drug toxicological testing labs and
eco-toxicological testing labs of health and drug monitoring,
chemical and environmental protection systems to meet the
requirements of REACH on chemical inspections. China should
strengthen consultation and communication with the European
Union, hold in-depth consultation on the mutual recognition of
chemicals testing data with the European Union through the
China-Europe Chemicals Working Conference established between
China Quality Inspection Bureau and the European Union, try to
pass the appraisal of experts from GLP certification agencies
and GLP labs and get the European Union to recognize testing data
made by Chinese labs. China should establish national chemicals
physical/chemical, toxicological and eco-toxicological
database network systems in collaboration with quality
inspection, chemical, health and environmental prote