Raising awareness about REACH and CLP Regulations for Turkish chemical industry and building up of regional industrial helpdesks
The project was implemented by a consortium of InfoMil, RPS and Grontmij. The consortium worked closely together with the Undersecretariat for Foreign Trade (UFT), the Istanbul Mineral and Metals Exporters Associations (İMMİB) and the Department of Chemicals Management of the Ministry of the Environment and Forestry (MoEF). UFT was the coordinating institution for the implementation of Customs Union and Association Council Decisions that focus on free movement of goods. İMMİB is an affiliated body of UFT. MoEF is the national competent authority for the harmonisation of REACH and CLP Regulations.
The project was a Government-to-Government (G2G) project, financed by the Dutch Agency for International Business and Cooperation (EVD) for the Ministry of Infrastructure and the Environment (IM).
The overall objective was to enhance capacity in public, semi-public and trade organisations to provide practical support to the chemical sector on the implementation of the REACH and CLP Regulations and raising awareness of the REACH and CLP Regulations.
As a general approach, the involvement of foreign experts in the training programme was most intensive during the initial activities in the project. Their involvement decreased with time and the trained Turkish trainers took over the role of the foreign experts as much as possible and as soon as possible. At the end of the project, a core group of trainers was formed with competence in the key parts of the REACH and CLP Regulations.
REACH is an EU Regulation on chemicals and their safe use (EC 1907/2006). It deals with the Registration, Evaluation, Authorisation and Restriction of Chemical Substances. The Regulation entered into force on 1 June 2007. The objective of REACH is to ensure that chemicals, during their full lifecycle, are managed in such a way that any significant risks to man and environment are prevented. REACH has been designed to manage and control the potential hazards and risks to man and the environment from the manufacture, import and use of chemicals.
In general, the REACH Regulation does not impact on companies outside the EU, but their exports to the EU may be affected by REACH. The importers established in the EU are primarily responsible for registering imported substances. In this respect, the EU importers rely on their non-EU exporter's information about the imported chemicals. For many non-EU exporters, detailed information about the chemical composition of preparations or about the chemical identity/identities of substances may be considered confidential business information which they do not wish to disclose to EU importers. The exporting company outside the EU may appoint an only representative (OR) as a legal entity to fulfil the REACH tasks of an importer in the EU and who is responsible for the registration obligations on behalf of the EU importers.
Consequently, the identified EU importers are regarded as downstream users of the OR and are not required to register the same substance. For that reason, the OR must keep a record of the listed importers including the imported volumes per importer. He will also be responsible for the information flow downstream by way of classifying and labelling the substance or preparation and by providing safety data sheets for the professional users downstream. The foreign company may not be part of the Substance Information Exchange Forum (SIEF), but most companies are setting up consortia as an effective manner of organising cooperation between participants of a SIEF, in which a non-EU company may participate.
Complementary to the REACH Regulation, a regulation on Classification, Labelling and Packaging of Substances and Mixtures (CLP) was adopted in December 2008 (Regulation No 1272/2008/EC) and came into force on 20 January 2009. The CLP Regulation will gradually replace the Dangerous Substances Directive (67/548/EEC) as of 30 November 2010 and the Dangerous Preparations Directive (1999/45/EC) as of 31 May 2015 and amended REACH Regulation. The Regulation is based on the Globally Harmonised System of Classification and Labelling of Chemicals (hereinafter referred to as 'the GHS') that has been developed in the UN context.
The following project results were achieved:
- Establishing a network of Industry helpdesks on the REACH and CLP regulations in regions where the chemical sector is clustered (İstanbul, Kocaeli, İzmir, Ankara, Bursa, Konya, Mersin).
- Improving the ability of regional helpdesk representatives to provide practical support to the chemical sector on the implementation of companies' obligations under the REACH and CLP Regulations.
Developing awareness and setting up an information programme to ensure that the Turkish Chemical Sector is informed about the REACH and CLP Regulation
- Directorate General for Export Undersecretariat of the Prime Ministry for Foreign Trade (UFT)
- Chemicals Management Department, General Directorate for Environmental Management, Ministry of the Environment and Forestry (MoEF).
- Export Promotion Centre of Turkey (IGEME)
- Istanbul Mineral and Metals Exporters' Associations (IMMIB) (Turkish Industry Helpdesk)
- Turkish Chemical Manufacturers Association (TKSD)
- The Union of Chambers and Commodity Exchanges of Turkey (TOBB)
- Small and Medium-Sized Enterprises Development Organisation (KOSGEB)
Duration of the project
The duration of the project was 18 months, 2010-2011. For further information please contact InfoMil.