ECHA s support to BPR helpdesks: state of play

Transcription

1 ECHA s support to BPR helpdesks: state of play CA-Dec13-Doc.5.1.f 54 th BPR MSCAs meeting December 2013, Brussels Henna Piha HelpNet Secretary, ECHA 05 December

2 ECHA s support to BPR helpdesks: state of play Overview of support activities in 2013 Harmonisation of replies and knowledge base Publication of frequently asked questions HelpNet Steering Group: current status and next steps 2

3 Overview of support activities in 2013 Support Workshop 06/2013 BPR FAQs kick/off 09/2013 BPR helpdesk correspondents appointment 11/2013 Communication webinar 11/2013 BPR FAQs publication 12/2013 HelpEx training & access 08/2013 HelpNet 8 agreement on enlargement 11/ days of BPR survey 12/2013 Visits to the BPR helpdesks of BE, FR, HU, IT, NL, SL and UK Participation of NL, SE and UK BPR helpdesks in HelpNet 8 3

4 Harmonisation and knowledge base Close contacts between ECHA and national helpdesks via HelpEx (web-based IT application) Discussion of issues related to the implementation of BPR, CLP and REACH Aim to achieve a common understanding of the legislative requirements Questions falling entirely under the remit of enforcement authorities and are outside the scope of HelpEx Issues for further consideration Questions relating to legal interpretation of BPR and their scope & relationship with other EU legislation Consultation of COM (or any other appropriate body) 4

5 Harmonisation and knowledge base BPR helpdesks/cas have been using the tool since August

6 05 December

7 Publication of FAQs Procedure FAQ updates in written consultation or fast track consultation Principles (I) Issues of general interest on obligations under the BPR Elaborate information on BPR guidance documents Consistent with BPR and existing guidance Based on HelpEx discussion Consensus: national BPR helpdesks (or CAs), COM and ECHA 9

8 Publication of FAQs Examples of questions currently proposed as BPR FAQs How to comply with the BPR for placing on the market treated articles which have been treated with, or include, biocidal products containing active substances? What will happen as of 1 September for in-situ generated substances that are now covered by the BPR but were not covered previously by the BPD? Is my product a treated article or a biocidal product or neither? Does BPR provide a role for Only Representatives? 10

9 Publication of FAQs Example of an FAQ Is my product a treated article or a biocidal product or neither? The decision whether a product is a biocidal product or a treated article or neither will always have to be taken case-by-case, considering all properties and functions, as well as the intended use of an article. A claim, for instance that an article itself is protected by a biocidal treatment, is likely to be considered a claim about a biocidal property rather than indicating a biocidal function, and is unlikely to drive a decision that the article would be considered a biocidal product. Member States may request the European Commission, according to Article 3(3) of the BPR, to take a decision whether a product is a biocidal product or a treated article or neither. More information on treated articles can be found in the Note for Guidance on Frequently asked questions on treated articles available on the ECHA website at: The guidance includes a decision tree which may help deciding whether an object treated with or intentionally incorporating one or more biocidal products is a treated article or a biocidal product or neither. 11

10 Publication of FAQs 12

11 HelpNet Steering Group: current status and next steps At HelpNet 8, the current HelpNet members (national REACH and CLP helpdesks, ECHA and COM) agreed on enlargement The BPR correspondents will be invited to HelpNet 9 (1-3 April 2014) HelpNet Secretariat to survey the expectations of BPR correspondents of HelpNet collaboration in Jan 2014 The results and the issues raised by the current members at HelpNet 8 will be compiled into a proposal by the HelpNet Secretariat to be presented at HelpNet 9 13

12 HelpNet Steering Group: current status and next steps Questionnaire to BPR helpdesks on HelpNet expectations 01/2014 Report on 100 days of BPR 03/2014 First enlarged BPR, CLP and REACH HelpNet Steering Group meeting 01-03/04/2014 Proposal for the operational handling of the expanded HelpNet 03/2014 BPR helpdesks membership confirmation at HelpNet 9 14

13 HelpNet Steering Group meetings: proposal R4BP Data sharing Classification & Labelling SMEs Steering Group Folio Cloud & HelpEx FAQ collaboration IUCLID SDS CLP Classification REACH IT Substance ID REACH 15

14 Steering Group meeting Workshop BPR CLP Workshop REACH 05 December 2013 Workshop (back-to-back to Steering Group meeting) 16

15 HelpNet is a strong partnership where its members take the lead in designing their collaboration! We welcome the BPR helpdesks to join. Henna Piha, HelpNet Secretariat help-net@echa.europa.eu