REACH
One of the cornerstones of FINAT: Representing the common interests of the European labelling community ‘Promoting the interests is a very common phrase in the mission statement of many trade associations and professional societies. It is, however, a very broad statement that can be interpreted in many ways -- but advocacy, lobbying and sector promotion are already firmly embedded in FINAT’s strategy and programmes. Not only are these key initiatives achieved via direct interaction with external ‘stakeholders’ such as politicians and authorities, related organisations in the packaging supply chain, NGOs, and trade media: they also involve the gathering of data, fact-finding, and the development of supporting tools and guidelines to help community members to address matters of public interest.
REACH, the largest item of chemical legislation in the world, is nearing its third deadline for registration. Any company that manufactures or imports more than 1 tonne per year of a chemical substance into the EU needs to register this chemical by the 31st of May 2018. FINAT members are reminded to check if any chemicals they supply or use are registered or planned to be registered, either by themselves or their suppliers. If this is not the case, urgent action is required, as no registration means no entry to the EU market! Information on the registration process and a wealth of other information can be found here.
Perhaps of even more relevance to FINAT members is the updated guidance on the requirements for substances in articles. The goal of this update is to reflect a ruling by the European Court of Justice in 2015 that states that each component article should be taken into account when calculating maximum levels for substances of very high concern (SVHC), instead of just the final end article as delivered. For example, rather than looking at a car as a whole, manufacturers would need to look at every individual bolt and part to see if any of these contain an excess level of SVHCs. The updated guidance document can be found here.
FINAT is participating in the CheMI platform for downstream users of chemicals under REACH to monitor developments and represent the self-adhesive label industry’s interests where needed.