When REACH is fully implemented, the administrative burden will grow exponentially, with potentially hundreds of millions of data sheets needing to be completed. While polymers are exempt from registration and only a limited number of monomers need to be registered, most additives used in products must comply with the regulation. This could become a complex and daunting challenge for many companies. "There is an urgent need for a shared chemical data platform that can help manage this process," said Su Shi, Director of the Production and Operation Management Department at Sinopec Corp., during a meeting on REACH regulations in the oil and chemical industry. More and more companies are echoing this call.
Recently, several companies have reported to journalists that the pre-registration phase under REACH will begin on June 1st this year. However, many data acquisition channels remain unclear. "If we don't register, we'll be excluded from the EU market. Downstream users won’t buy raw materials from companies without pre-registration, as they want to ensure their products meet regulatory standards. The domestic market will shrink as well. But if we do register, we don’t know where to start or how to collect all the required data," said the head of a private company in Shandong, expressing frustration. As the pre-registration deadline approaches, many firms are scrambling, some even feeling lost.
According to Yang Weicai, vice president of the China Petroleum and Chemical Industry Association, REACH registration involves different departments and requires varied data sources—such as physical and chemical data from the chemical sector, environmental toxicity data from the environmental protection department, and human toxicological data from the health system. He emphasized that REACH pre-registration and registration not only affect individual companies but also have broader implications for the industry's development and downstream sectors.
Pan Derun, deputy chairman of the Petrochemical Association, noted that as a new law, REACH lacks clear guidelines on certain aspects. "Many things are still uncertain. I hope all stakeholders can work together to overcome these challenges." He suggested that the government should establish a national chemical safety and health information center to facilitate data sharing and better support enterprises.
Wang Nongyue, general manager of Shanghai Shengao Group, highlighted the importance of joint registration to reduce costs. While REACH mandates the sharing of vertebrate animal test data to minimize animal testing, few companies currently emphasize the benefits of information sharing. Wang believes the greatest advantage of joint registration lies in resource sharing and reducing unnecessary waste of time, money, and labor.
It is understood that companies are eager to create a national chemical data-sharing platform to avoid redundant testing. Domestic testing costs are significantly lower than sending samples to the EU. Many hope the government will support industry testing centers so they can gain EU recognition quickly. They also urge the government to join the GLP (Good Laboratory Practice) organization as soon as possible, enabling international data mutual recognition and lowering compliance costs for Chinese enterprises.
In terms of vertical information sharing along the supply chain, Zhang Xiangchen, director of the World Trade Organization Department at the Ministry of Commerce, stated that downstream users are not indifferent to REACH registration. They must collaborate with upstream suppliers to provide usage and exposure scenario data to ensure chemical safety information flows through the entire supply chain and protects consumer health. Su Shi echoed this sentiment, noting that REACH affects over 90% of EU product exports, involving the whole industry chain. He stressed that regardless of who registers, complete supply chain information must be provided. He hopes upstream and downstream companies will communicate promptly to inform suppliers about the use of raw materials, including their application and related exposure scenarios in chemical safety assessments.
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