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Industry News March 2022
Parachem

We recently received a communication from DEFRA via the HSE regarding downstream user duties under UK REACH. It is very relevant for ICT member companies.

Important news regarding "Reach" Article 33 – Duty to disclose information about SVHC conatained in manufactured items.

The Department for Environment, Food and Rural Affairs (DEFRA) has launched a survey via the HSE e-Bulletin service in order to:
a) Assess the levels of awareness of the duties under Article 33, and
b) Understand businesses’ practical experience of implementing and complying with these duties.

Article 33 states that:
1. A manufacturer / supplier of an article containing a SVHC must disclose information about any SVHCs contained to the recipient. This duty applies all the way down the supply chain to the retailer of the manufactured item.
2. The retailer of the article must supply this information to the public within 45 days of a request from any consumer.

DEFRA states that previous research conducted in the EU found that levels of awareness are low and that there are difficulties in implementation. This disclosure duty has been a statutory legal duty since 2009, but many manufacturers and suppliers are not aware of it. The duty still applies to all UK manufacturers, suppliers and retailers after Brexit.

The communication from DEFRA confirms that “The Secretary of State for the Environment, Food and Rural Affairs is required to review Article 33 to assess its practical operation and whether or not to extend the scope beyond SVHCs to cover other dangerous substances such as skin sensitisers.”

ParaChem’s online compliance tool “ReachWARE®” has been updated after Brexit to cover the requirements of the new UK REACH and allows users to fulfil all disclosure duties under EU REACH and UK REACH. It will also include skin sensitisers if the scope is extended as
described above.

SPECIAL OFFER FOR NEW SUBSCRIBERS TO REACHWARE®
What is REACHWARE®?
ReachWARE® is an online database for manufacturers (“downstream users” of chemicals) that have a legal duty to make disclosure reports under “The REACH etc. (Amendment etc) (EU Exit) Regulations 2019” (UK REACH)”.

It also facilitates compliance with;

EU REACH Reporting Duties
CONFLICT MINERALS Reporting Duties
ROHS3 Reporting Duties
FULL MATERIAL DISCLOSURE (FMD) Reports
WASTE FRAMEWORK DIRECTIVE (WFD) Reporting Duties

What’s the deal?

Any ICT corporate or individual member can subscribe to ReachWARE® for a reduced monthly fee. The subscription is normally £60+VAT per month, and this will be reduced to £45+VAT per month for twelve months for ICT members taking out a subscription in April 2022. Furthermore the £199+VAT set-up fee will be waived throughout April 2022.

There is no tie-in period and you can terminate your subscription at any time.

How do I sign up?

You can see information about ReachWARE® on our website before subscribing. There are downloadable guides to help with all aspects of using ReachWARE®.

Go to our website parachem.co.uk and register your interest. All enquiries received on or before 30th April 2022 will qualify for the discounts described above.
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