Thanks to our Biocide Team who support industries doing simplified authorizations during this current COVID 19 crisis. 👏

👉 Meet us at the ACI Biopesticides Europe conference on 7 & 8 October in Brussels

REACH requirements 

RRA could help you to deal with your REACH requirements. The first step is to set your frame. We could support you to answer the following questions:

• Are you a manufacturer, an importer or a downstream user?
• What is your current/planned tonnage?
• Is your substance already register or not?
• Do you have to generate new laboratory studies?
• Do you have to inquire to ECHA?
• Do you have to generate a CSA/CSR?
• What are the costs (letter of access, new studies, fees to ECHA and consultancy fees)?

Here is an example: you import a substance already registered at tonnage of 10 tons per year. What do you have to do to get your registration?

The first step is to characterize your substance. We could help you to define if your substance is a mono-constituent or a UVCB substance and help you to find a laboratory that could identify your substance.

As soon as your characterization is available, you could inquire with ECHA to check if a registration is already available. We could help you to generate this dossier using IUCLID 6 and to send it to ECHA via REACH-IT.

Within the 20 working days, you should receive feedback from ECHA in order to initiate data sharing and to submit a joint submission if potential registrant is already existing.

If you are the first to register the substance, we could help you to find a laboratory that meets your expectations, to monitor your studies and to fulfill your dossier.

If you are not the first to register, we could help you to converse with the lead registrant to get data access and to fulfill your dossier.

In both cases, we implement the relevant actions to build your dossier in order to get your registration.

The range of "amateur" uses the strengthening of authorization conditions for France.

The decree published by the Ministry of Agriculture on 10 April 2020 strengthens the requirements for the authorization of Plant Protection Products for "amateur" uses (law No. 2014-110 of 6 February  2014).

Since 1 January 2019, the law forbids the sale, delivery, use, and possession of plant protection products for non-professional use except:

• biocontrol products appearing on the list established by the Ministry responsible for agriculture (articles L.253-5 and L.253-7 of the Rural Code),
• low risk products in accordance with regulation (EC) n ° 1107/2009 (art. 47),
• products whose use is authorized within the framework of organic farming (Regulation (EC) n ° 889/2008).

Moreover, this decree brings new hazard statements concerning the issuance of marketing authorizations for the "amateur" range for products and for the active substances contained in the product. In particular for products within an active substance considered as an endocrine disruptor or a persistent organic pollutant, products can’t be authorized in the range of "amateur" uses.

This decree also excludes the following formulations:

• powder for dusting (DP),
• wettable powder (WP), except for single-dose packaging or any other dosing system excluding user contact with the product.

New requirements concerning the label and packaging are also specified in the decree.

First cumulative pesticides risk reports published by EFSA.

EFSA has published results concerning 2 assessments regarding human risks related to residues of multiple pesticides potentially found  in food.

You can find the really encouraging conclusion here.