ECHA’s Forum for Exchange of Information on Enforcement recently published its “Strategies and minimum criteria for enforcement of chemical regulations”. The Forum is a network of authorities responsible for the enforcement of the REACH, CLP and PIC regulations in the EU, Norway, Iceland and Liechtenstein.
Amongst other elements, the document features a ranking list of prioritization of controls based on REACH (and CLP) duties provided by the Member States. With respect to the priorities in the area of REACH, the ranking list encompasses the following actions to be taken by companies:
1. Information in the supply chain
2. Restrictions on the use of hazardous substances
3. Registration of all substances and those in mixtures
4. Relevant information for imported goods
5. Authorization for certain use of hazardous substances
6. Obligation to communicate information on critical substances in articles
7. Registration and notification of critical substances in articles
It is worth noting that non-compliance in the product-/chemical area can lead to considerable fines and/or penalties.
According to this list, Art. 33 of the REACH Regulation is ranked 6th in the list of enforcement priorities. Essential legal requirements related to supply chain transparency (and regarding Art. 33 specifically) can be found in the annex of the document.
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