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Product Compliance –  2018

Product Compliance –  2018

The European Union (EU) REACH Regulation updates in 2017 included a lot of new substances. The Environmental Protection Agency also started to implement several amendments to the Toxic Substances Control Act of the United States.

There are series of regulatory changes that are expected to occur in 2018. In-scope companies will be expected to meet latest requirements throughout several product compliance regulations, with REACH Regulation and RoHS Directive not left out.

Below is a list that highlights the developments that will be vital in compliance, as predicted by some of our reliable experts.


Proposition 65 Labeling Requirements

On the 30th of August, 2016, Proposition 65 – Article 6 of the California Safe Drinking Water and Toxic Enforcement Act – was amended. The amendment helped in clarifying the warning label requirements. It is expected that new requirements will be effected on 30th of August, 2018. When it does, labels and signage must include:

  • Name of one or more Proposition 65-listed substance
  • Pictogram for enhanced visibility
  • Short or long form warning.

Suppliers are advised to personalize warnings to their respective industries. Companies are expected to comply with the newly amended rules, if not, they will face a fine of $2,500 daily, including further legal actions.



RoHS Phthalate Elimination

Furthermore, there are additional restrictions on four phthalates that are anticipated to be effected on the 22nd of July, 2019. The substances include:

  • Benzyl butyl phthalate (BBP)
  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)


Companies that currently sell or supply products that contain any of the substances listed about in the EU are expected to fact fast so as to meet these latest requirements.


New UAE RoHS Restrictions Come Into Effect

As of the 1st of January, 2018, new restrictions will come into effect for substances and chemicals that are being sold or supplied in (UAE). The substances include:

  • Lead (Pb)
  • Cadmium (Cd)
  • Mercury (Hg)
  • Polybrominated diphenyl ether (PBDE)
  • Polybrominated biphenyls (PBB)
  • Hexavalent chromium (Cr6+)

Any company that is yet to sort out their obligations under the regulation should kindly do so in 2018. As the restrictions have been forcefully implemented, companies need to start looking forward to the next UAE RoHS deadline.


REACH Candidate List Updates

On 15th of January, 2018, seven news substances were added to the REACH Candidate List by ECHA. They include:

  • Chrysene
  • Cadmium nitrate
  • Benz(a)anthracene
  • Cadmium carbonate
  • Cadmium hydroxide
  • Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde, and 4-heptylphenol, branched and linear (RP-HP) (with ≥0.1% w/w 4-heptylphenol, branched and linear)
  • 1,6,7,8,9,14,15,16,17,17,18,18- Dodecachloropentacyclo[,9.02,13.05,10]octadeca-7,15-diene (“Dechlorane Plus”TM) (covering any of its individual anti- and syn-isomers, or any combination thereof)
  • Bisphenol A has also been updated to contain its environmental endocrine-disrupting properties. Companies are expected to start gathering necessary information about these substances.


REACH Registration Deadline

Lastly, the 31st of May, 2018 will mark the final deadline for REACH registration. Any substance or chemical imported into the EU after that day, at more than a ton per annum, must be registered with the ECHA.


To know more about how our TPP team can help your get in touch with us today. Our team will be available to provide answers to all of your questions.