Since the EU REACH legislation into the pre-registration stage, the China Leather Association has been closely watching the progress of laws and regulations, because the regulation of chemicals is not just chemical products, its actual scope of influence includes chemical products and chemical substances in the downstream product. Taking into account the future regulations may have an impact on the leather industry in China, we have the first time with the International Leather Council has made contact with the International Leather Council Secretary-General Paul Pearson Sen in his busy schedule to accept our interview, the REACH regulations The latest developments are described, and elaborated REACH regulations on the leather industry. REACH regulations on the impact of the leather industry can not be generalized. China Leather Association: In what ways does REACH affect the leather industry (including leather, fur, leather, shoes, bags, clothing, leather hardware and leather machinery)? Paul Pearson: The REACH legislation is mainly affected by chemical manufacturers within the EU and companies that provide chemical products to the EU, such as chemical product suppliers or leather and leather product manufacturers that import chemical products directly from outside the EU. Chemical products suppliers outside the EU have brought their products into the EU and have to reach an agreement with their customers in the EU to register necessary chemical products and keep a large amount of information available at all times. The tannery and leather goods factories in the European Union need to check with their suppliers of chemical raw materials whether the chemical products provided to them can continue to be used. If these chemical products have not yet registered, then the import of chemical tannery and leather products factory will be responsible for registration. REACH has less legal restrictions on companies exporting leather and leather products to the European Union, but they must also provide EU importers and retailers with important product information. In the newly released guidelines on the material requirements of articles in the guideline, this regulation has been further elaborated and explained. REACH requirements under normal predictable conditions, which may release the total amount of material if more than 1 tonne / year, according to the basic requirements of REACH regulations, according to the weight to determine the registration period and provide the required information on the Substance registration. However, this is only for items that will release material under normal foreseeable conditions of use. For example, textile products laundered in the country should not be considered released after they have been exported to other countries. Therefore, in addition to some special circumstances, this situation on leather and leather products is relatively small. Except for the cases mentioned above, items exported to the EU do not need to be registered for the substances contained therein. However, if an article contains SVHC listed in the "Candidate List" by the European Union, it must be notified to the European Chemicals Agency if it contains more than 0.1% of the articles and the total is more than 1 tonne per year . This is a much simpler task than registration, and it is an obligation for importers to rely on their suppliers to provide details of the substances contained in the items or to prove that they do not exist. Importers also have the obligation to inform their customers and consumers about the high levels of concern in their products. British authorities require importers to provide this information to customers and consumers within 45 days. Any individual and organization has the power to obtain chemical information from the item within 45 days from the retailer. The list of SVWs is not yet available and is expected to be released by June 2009, but previous legislation gave some clues as to what may be on the list. It is recommended that companies detect the content of substances entering the European Union and exclude substances that may be defined as substances of high concern to avoid affecting the products entering the EU. For companies outside the EU that produce leather and leather products and target exports to the European Union, the same holds true for their potential impact. The only difference may lie in their place in the entire industry chain and the number of suppliers they need to get information on raw materials and components. For the suppliers of leather machinery, the REACH regulation will not cause any significant effect. The only possible impact is that the leather manufacturers will come up with the requirement of good control over the chemical content of products and guarantee of stability and uniformity. It is a business question whether leather manufacturers need to register China Leather Association: For leather manufacturers, they may be directly affected by REACH regulations, but their raw materials are often derived from upstream chemical intermediates, and leather materials are often a mixture, then leather manufacturers and their Of raw material suppliers, who should fulfill the registration obligations? Paul Pearson: This should ultimately be a commercial issue. From a legal point of view, if a chemical is not yet registered, its EU producer or importer importing it from outside the EU to the EU is legally registered. For mixtures and preparations, the registration should, of course, be undertaken by the manufacturer of the chemical when the supplier is from within the EU; in the case of a chemical mixture imported into the EU, the importer must ensure that the substance in the product is registered . He needs to negotiate with his overseas suppliers and manufacturers to do the job. First he needs to know the composition of the mixture and then provide enough information necessary to complete the registration. If overseas exporters want to continue their trade with the EU, they will certainly cooperate with the EU's importers or complete their registration. Leather and leather products have an indirect impact China Leather Association: In addition to leather chemicals industry, do you think the finished leather and leather products will be affected by this regulation? If so, in what ways will it be affected? Paul Pearson: In the answer to question 1, the relevant regulations for tanneries, leather goods producers and importers and exporters in the European market have been listed. For "downstream processing", the most important issue in Europe is that compared with the EU countries, the range of chemical materials now available in Europe and the scope of new chemical materials for new uses developed in the future will be severely restricted. At the same time The final product that is not made in Europe will still be imported into EU countries. For non-EU leather and leather goods suppliers, the biggest impact will come mainly from their customers - customers will ask manufacturers to ensure that the products they supply do not use "high degree of concern" of ingredients. Enterprises should be clear in the supply chain position China Leather Association: In order to adapt to these closely related laws and regulations of the leather business, you suggest that enterprises do what kind of preparation? PaulPearson: First of all, the position of the enterprise in the supply chain and the regulations and previous information related to the enterprise should be clarified. The second is to test the chemical materials used for the chemical products supplied by the enterprise products and whether they contain the ingredients that are included in the "high degree of concern", if any, to what extent. Companies need to dialogue with suppliers to determine the company procurement of products and the ingredients used in the chemical composition, it is best to be able to list the ingredients of all products and ingredients to identify what ingredients should be informed customers. Businesses will receive a large number of customer requests for information on the composition and to prepare for this. Some customers will ask for a lot of unnecessary extra information, so it is important for the business to know what information is really what customers want and respond appropriately. There are differences in the registration of enterprises with different production volumes China Leather Association: What are your suggestions for the preparations for the enterprises with output of 1-100 tons, 100-1000 tons and enterprises with 1000 tons and above? Paul Pearson: There is no difference in principle - it's just the difference in time. There is almost no difference between the "goods" suppliers in the European market. A pre-registration of 6 months beginning on June 1, 2008 is a crucial step in the process, and any material that has not been pre-registered will be excluded from the market. For any application of chemical products, if you want to register for use, you must first pre-register. After pre-registration, the formal registration is divided into 3 categories: Registered as of November 30, 2010: Chemicals of a production or import volume greater than or equal to 1,000 metric tonnes; Substances that are carcinogenic, mutagenic, mutagenic, toxic Substances; substances (R50-53) that are "extremely toxic to aquatic organisms and cause long-term toxic effects to the aquatic environment", chemicals exceeding 100 metric tons. As of June 1, 2013, chemical substances with a production or import volume between 100 and 1000 metric tons were registered. As of June 1, 2018, chemicals with a production or import volume of between 1 and 100 metric tons were registered. European agencies and businesses are fully prepared to respond China Leather Association: What laws and regulations related to the various departments and enterprises in Europe have done preparatory work? PaulPearson: Overall, the European Chemicals agency at the national and the branches are working together to promote legislation and regulations to implement on time, they have been well prepared, although individual agencies may to varying degrees. Most large EU countries are also well prepared to compile a list of the chemicals they use. The situation of small enterprises is complex and their level of understanding is different, which may result in inappropriate data needs. The pre-registration is now in its infancy, with the main uncertainty being the content of the "high degree of concern" component of the candidate list. It remains controversial whether this list covers a comprehensive list of all substances, or simply lists that contain only the key substances.