Copper is mainly used in industry (industrial chalcopyrite to produce copper) The impact of REACH on our copper production and processing enterprises and downstream users REACH has been highly concerned by the domestic chemical industry, but domestic non-ferrous enterprises are still in the stage of understanding or even not understanding this regulation. The implementation of REACH will bring many unfavorable factors to our non-ferrous enterprises in the aspects of product registration and inspection. Therefore, we must attach importance to the EU REACH regulation and take countermeasures as soon as possible.
As a copper and copper processing company, if it is currently exporting its products to Europe, it must do the following :
1. Create a detailed list of the various substances contained in the product.
2. Identify whether each substance is subject to the producer and importer responsibilities set out in r each Regulation.
3. Establish a long-term dialogue mechanism with upstream suppliers and downstream users.
4. Prepare for separate business pre-registration in the second half of 2008.
5. Provide necessary data and information. In the past, REACH did not require businesses using scrap copper as a raw material to register. But under the latest revision, companies that use scrap copper will also need to undertake the obligations set out in REACH and register separately.
Direct export volume of our country is not large at present, and is mainly affected by levapping export tariff. It is estimated that China will be a net importer of electric copper for a long time to come. In this sense, the implementation of REACH has little impact on Chinese electric copper producers in the short term. However, if we do not actively participate in the REACH regulation, our copper businesses may lose the current favourable period of pre-registration. In other words, if China adjusts its copper export policy and lifts export restrictions in the future, copper companies will have to re-register to enter the EU market. In addition, from the whole copper industry chain, there are many copper processing enterprises and manufacturing enterprises that use copper in our country. When their products are exported to Europe, they will be affected by REACH. First of all, copper processing enterprises, as the downstream producers of our electric copper, must prove that the chemical substances contained in their products have been registered in accordance with the REACH regulation when entering the European Union market, otherwise the products themselves cannot enter the European Union market. At the same time, the REACH regulation stipulates that the registration subject must be a company with legal person status in the European Union. So if Chinese manufacturers intend to continue exporting to Europe, they must choose an exclusive agent in the EU with legal status to help them register and maintain their data over the long term. This undoubtedly increases the export cost of enterprises. In addition, downstream products of copper, such as hardware devices and electrical appliances, involve the use of copper. Upstream suppliers will also be required to provide documentation when their products are exported to the EU market. The implementation of the REACH regulations is a complex process, and domestic enterprises need to make clear the importance and urgency of pre-registration. First of all, there are no additional fees to be paid during the pre-registration process, which is very small compared to the fees required during the registration process. Second, after the completion of pre-registration, enterprises enjoy different periods of transition according to the declared tonnage. Companies will still be able to export to the EU during the transition period. Third, domestic copper enterprises establish a dialogue mechanism with European copper research institutions through their own companies with independent legal personality in Europe, or through the designation of the sole agent in Europe. Join the association of the Agency specifically set up in response to REACH to undertake some basic research work for registration, particularly research work involving biological experiments and toxicity analysis. At the same time, we can share some research results already done by European copper research institutions. As REACH is not yet fully effective, it is difficult to estimate the impact on China's copper industry chain. However, for enterprises that are already engaged in copper processing products and products in the copper industry chain and export to the EU, they must take a comprehensive consideration from the following aspects as soon as possible.
1. Full and detailed understanding of REACH regulations and relevant content of the industry.
2. Establishment of joint coping mechanism for Upstream and downstream cooperation of copper industry Chain.
3. Get in touch with European Copper Research institutions to complete pre-registration as soon as possible through agents or branches or as a downstream customer to complete the necessary information transfer.
4. Actively develop other export markets to avoid risks. At present, in China's copper industry chain, various export products account for more than 20% of the total copper consumption in China. Once the REACH regulation takes effect, it will undoubtedly increase the export cost of our country's copper industrial chain products and reduce the export competitiveness. Therefore, it is necessary to develop export markets of other countries and regions.
Post time: Dec-15-2022
