EFEO Keyvisual

E.F.E.O. and REACH compliance: A history of support to the branch

Since 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. organized many meetings, workshops, webinars and conference calls to facilitate the formation of consortia. The consortia were organized in 3 steps, in line with the deadlines set by ECHA:

  • Phase I started from scratch in 2008 and which included the products which needed to be registered by 2010:
    citrus and mint, the safrole-containing Essential Oils and vetiver.
  • Phase II started in 2011 and included a.o. the products which needed to be registered by 2013.
  • Phase III For registration in E.F.E.O. initiated their “act now” program in 2016 in order to call companies for registration within the last deadline expiring by 31st May 2018. E.F.E.O. was reinforcing the support to the consortia by putting together a specific action plan to finish off the registration process. For Phase III, E.F.E.O., working closely with IFRA, was able to bring ECHA to a better understanding of our concerns.

Having effectively guided the consortia through the registration process, E.F.E.O. will continue their support in REACH matters where requested by the companies. REACH has not come to a standstill after 1st June 2018, and there will be many future challenges to be dealt with by the consortia, such as the improving and updating of the registration dossiers. Companies are well aware that REACH implementation and compliance will be subject of increased inspections by the authorities in the EU member States.


Important REACH related documents

ACT NOW

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:

ACT NOW Paper         ACT NOW questionnaire

FAQs on REACH

Frequently asked questions - REACH information from ECHA, see this link

Obligations and Liabilities of the Lead Registrant in the SIEF - CEFIC document under this link

Link to ECHA National Helpdesk

 

 

 

 

 

NCS Guidance Documents

 

E.F.E.O./IFRA GUIDELINES ON SUBSTANCE IDENTIFICATION AND SAMENESS OF NATURAL COMPLEX SUBSTANCES (NCS) UNDER REACH AND CLP 

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E.F.E.O./IFRA Guidelines on the Environmental Assessment of Natural Complex Substances (NCS) 

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E.F.E.O./IFRA A case study on value chain cooperation and constructive, commited dialogue with authorities to address unintended regulatory consequenses


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Presentations

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.