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The REACH Regulation in the footwear industry

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    REACH (Regulation no 1907/2006 of the European Parliament and of the Council) is the European regulation relative to the Registration, Evaluation, Authorisation and Restriction of Chemicals. This Regulation came into force on 1st June 2007, and its main objective is to ensure a high level of protection of human health and the environment with regard to the use of chemicals.


    The REACH Regulation places responsibility on industry to manage the risks from chemicals and to provide safety information on the substances produced, imported, marketed and used in the processes. Therefore, each company must meet one or several requirements established in the Regulation according to the type of chemicals or preparations produced, used and/or imported, their origin (whether they come from the European Union or not) and how they are applied in the industrial processes. The future of the footwear and footwear components industries, such as tanneries, adhesives manufacturers, and soles manufacturers, among others, is determined in the European Union by this Community Regulation.


    The European Chemicals Agency (ECHA) is the official body in charge of coordinating all the Member States of the European Union to comply with that Regulation. It is at the helm of the regulating authorities for applying UE legislation on chemicals.


    One of the main objectives of the REACH regulation is to increase information on chemical substances and their associated risks, and to convey such information to the different actors in the supply chains of industrial sectors. To this end, the REACH Regulation established a procedure for compliance, which is divided into the following stages:


    1.Registration: Registration is compulsory for all substances manufactured or imported in the European Union in quantities of one tonne or more per year per manufacturer or importer, except those which are exempt from the obligation to be registered (risk-free polymers and substances). This includes substances as such, in the form of mixtures or contained in articles when they are intended to be released under normal or reasonably foreseeable conditions.
    2.Evaluation: The European Chemicals Agency (ECHA) is charged with assessing the registration dossiers.
    3.Authorisation: This procedure is used for substances that are of extremely high concern (SVHC) and are listed in Annex XIV of the Regulation. The main objective of Authorisation is to ensure the correct functioning of the domestic market and guarantee that the risks arising from the Substances of Very High Concern (SVHC) are property controlled. Manufacturers, importers or downstream users of a substance included in the Authorisation List (Annex XIV) can apply for authorisation. Downstream users who do not apply for their own authorisation may use a SVHC substance providing that it is used in accordance with the conditions of authorisation granted to an agent further up the supply chain for that use.
    4.Restrictions: Restrictions are an instrument for protecting human health and the environment from unacceptable chemical risks. The restrictions can limit or prohibit the manufacture, placing on the market or use of a substance and can be applied to any particular substance in a mixture or in an article. They are also compulsorily applied to imports.


    Apart from processes, there are three groups of critical substances to be taken into consideration:
    1.Restricted Substances List (Annex XVII of the REACH Regulation): these substances are limited or prohibited for certain uses.

    2.List of Substances Subject to Authorisation (Annex XIV of the REACH Regulation): these substances cannot be used, unless there is express authorisation for specific uses.
    3.List of Substances of Very High Concern that are candidate to be included in Annex XIV of the REACH Regulation (this list is posted on ECHA’s website). Although there is no limitation or prohibition on these substances, their use imply certain obligations to be complied with.

    The REACH regulation calls for information flow within the whole supply chain (downstream and upstream). The main communication tools to be employed are the safety data sheets and supplier-customer letters.


    The obligations established in the REACH Regulation for the different actors in the footwear supply chain are defined below.


    Manufacturers or importers of substances (solvents, tanning agents, etc.) shall register those substances manufactured/imported in quantities of 1 tonne or more per year for that specific use. In addition, they shall indicate the possible uses and registration number of each substance in the safety data sheets.


    Manufacturers or importers of preparations (adhesives, dyestuffs, finishing products, etc.) shall ensure that their preparations do not contain any of the substances included in the Restricted Substances List in concentrations above the maximum limit allowed. Also, they shall verify if their preparations contain any of the substances included in the List of Substances Subject to Authorisation. If so, they shall ask the ECHA for authorisation for that specific use. They shall inform their customers about the presence of a Substance of Very High Concern in their preparations through the safety data sheets, and shall verify, in the safety data sheets or in the ECHA’s website, if the substances they use are registered for the intended use.


    Producers or importers of components (soles, leather, etc.) shall ensure that their components do not contain any of the substances included in the Restricted Substances List in concentrations above the maximum limit allowed. They shall also verify if their components contain any of the substances included in the List of Substances Subject to Authorisation. If so, they shall ask the ECHA for authorisation for that specific use. They shall inform their customers if a Substance of Very High Concern is present in their components in concentrations above 0.1% by weight. They shall verify, in the safety data sheets or in the ECHA’s website, if the substances they use are registered for the intended use. Additionally, they shall notify the ECHA of the presence of a Substance of Very High Concern in their components, when these three conditions are met:
    1.The substance is present in the component above a concentration of 0.1% by weight.
    2.The total quantity of the substance used or imported exceeds 1 tonne/year.
    3.The substance has not yet been registered for that specific use.


    Producers or importers of finished goods (footwear) shall ensure that their articles do not contain any of the substances included in the Restricted Substances List in concentrations above the maximum limit allowed. Also, they shall ask their suppliers for information to verify if the preparations or the components they use contain any of the Substances of Very High Concern

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