How E.F.E.O. supports the membership for REACH compliance
Since in 2003, E.F.E.O. devoted lots of time and effort by participating among others to the public hearing on EU chemical White Paper, where E.F.E.O. submitted a statement; to the SPORT project in 2004; to the first survey on tonnage bands in 2005; to the EFFA REACH Task Force; to RIP 3.10 and by making several visits to ECHA in Helsinki to present our Protocol and discuss problems arising during the registration process due to the nature of Natural Complex Substances (NCS).
In September 2006, the first ever common position for the whole supply chain on REACH was presented to the EU Commission. This led to the agreement that Essential Oils were to be considered as NCS (Natural Complex Substances). It resulted in two amendments that were added to the REACH regulation.
Starting in 2007 and up till now, E.F.E.O. paved the way to the establishment of consortia for NCS registration. Together with its partners, EFFA and IFRA, it set up a protocol for the definition of NCS that has become the standard. E.F.E.O. organised many meetings, workshops, webinars and conference calls to facilitate the formation of consortia. The consortia were organised in 3 steps, in line with the deadlines set by ECHA:
- Phase I: Which E.F.E.O. started from scratch in 2008 and which included the products which needed to be registered by 2010 : citrus and mint, the safrol-containing Essential Oils and vetiver.
- Phase II: Which started in 2011 and included a.o. the products which needed to be registered by 2013.
- Phase III: For registration in 2018 (started in 2014). The first two phases are now running on their own with E.F.E.O. continuing to insure coordination, overall when it comes to the acceptance of the registration criteria and dossiers by ECHA, an organisation critical to the SMEs as they benefit from the preparation work, data collecting and cost lowering.
For Phase III, E.F.E.O., working closely with IFRA, was able to bring ECHA to a better understanding of our concerns. E.F.E.O. is also reinforcing the support to the consortia by putting together a specific action plan to finish off the registration process.
Mid 2018 is around the corner. This is the last deadline to get the registration finalised for all Essential Oils/NCS produced or imported at quantities over 1 ton per year.
E.F.E.O. has the tools to help, but it is up to the producers and/or importers to register, so it is time to act now!
Important REACH related documents
After 31st May, 2018, Essential Oils > 1 ton p.a. used i.a. in fragrance and/or oral care applications may only be further produced or imported if registered with the ECHA (European Chemical Agency). With a view to the expiry of the deadline in less than 2 years from now, there is an urgent need for action: No registration- no market!
In order to support our companies, E.F.E.O. has issued recommendations to importers/producers who have pre-registered their product portfolio but have not made further efforts towards registration mainly because they have not yet finally decided whether or not to submit registration dossiers.
Please find hereunder our E.F.E.O. information paper and questionnaire:
NCS Guidance Documents
E.F.E.O./IFRA GUIDELINES ON SUBSTANCE IDENTIFICATION AND SAMENESS OF NATURAL COMPLEX SUBSTANCES (NCS) UNDER REACH AND CLP
E.F.E.O./IFRA Guidelines on the Environmental Assessment of Natural Complex Substances (NCS)
E.F.E.O./IFRA A case study on value chain cooperation and constructive, commited dialogue with authorities to address unintended regulatory consequenses
5a Conferenza nationale sul Regolameno REACH, 19th November, 2016 in Rome
Testimonianza sulla registrazione Reach dell’essenza di mandarino da parte di un’azienda italiana in qualità di Lead Registrant - Italien Language only
by Mr. Raymo Vilfredo - Simone Gatto s.r.l.