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Control of Detergents on the Greek market

Control of Detergents on the Greek market. TAIEX SEMINAR September 21 st & 22 nd 2009 Bucharest -Romania Presented by: Sophia Antoniadou – PhD chemist General Chemical State Laboratory Division of Raw materials & Industrial products Athens – Greece. Legislative framework.

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Control of Detergents on the Greek market

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  1. Control of Detergents on the Greek market TAIEX SEMINAR September 21st & 22nd 2009 Bucharest -Romania Presented by: Sophia Antoniadou – PhD chemist General Chemical State Laboratory Division of Raw materials & Industrial products Athens – Greece

  2. Legislative framework • Regulation (EC) 648/2004, as amended. • in force since 08.10.2005 • amendments: Reg. (EC) 907/2006, 551/2009 (replacement of Annexes III and VII, V and VI) • articles 8, 10 and 18, mandate the member-states to lay down provisions for the enforcement of the Regulation.

  3. Legislative framework (continue) • article 8mandates the member-states to appoint: • the Competent Authority responsible for the management of the Regulation and • the approved laboratories, for the performance of the tests required by the Regulation, certified according to ISO 17025 or GLP “Good Laboratory Practice”

  4. Legislative framework (continue) article 10mandates the member-states to apply • all necessary control measures to detergents placed on the market, to ensure compliance of the product with the provisions of the Regulation article18mandates the member-states to apply • sanctionsin case of infringements .

  5. Legislative framework (continue) Pursuant to the provisions of these articles, in Greece a Ministerial Decision is adopted arranging the following: • national Competent Authority • labelling of the products in native language • measures for the control of the market • fees , penalties and sanctions • entry into force and repealed legislation

  6. Measures for the control of the market • In order to apply the most appropriate measures, the following points were considered: • what kind of enterprises are operating in our country • the kind and the origin of products circulated in the market • the environmental parameters • the geographical parameters

  7. (continue)Measures for the control of the market • The facts are the following: • majority of the enterprises: medium and small (national & international of large size <15) • all kinds of products • origin: either EU or third countries (mainly from Italy, Spain, France, Germany,UK as well as China, Turkey, India, Israel etc.) • almost 50.000 km of coastline in the eastern part of Mediterranean Sea • Southeastern external border of EU

  8. (continue)Measures for the control of the market • Control measures shall be : • easy & fast to apply • effective • personnel & equipment saving • oriented : 1stto check relevant documents 2nd to inspect 3rd to laboratory analysis

  9. ((continue)Measures for the control of the market Check of the data for the surfactant and/or the product: 1. biodegradability of the surfactant(s) 2. composition and physicochemical parameters 3. classification andlabelling

  10. (continue)Measures for the control of the market Other measures : 4. Registration in the “Registry of Cleaning Products” 5. Inspections at production / packaging / storage / distribution premises and retailers 6. Samplingof products from the market and performance of full scale laboratory analysis.

  11. Check of the biodegradability of surfactants • Check in the MSDS of the surfactant: • point 12 “ECOLOGICAL INFORMATION” there shall be mentioned: the result of at least one biodegradability test according to the methods of Annex III of the Regulation example of wording : “threshold values for OECD 301D method are reached” or “ultimate biodegradability > 60% , CO2 liberation “ meaning by : OECD 301D, the method of Dir. 67/548 Annex V.C. 4-E OECD 301B, the method of Dir. 67/548 Annex V.C. 4-C

  12. (continue)Check of the biodegradability of surfactants • Check in the MSDS of the surfactant: • point 16 “OTHER INFORMATION” shall mention: “The surfactant(s) contained in this preparation complies (comply) with the biodegradability criteria as laid down in Regulation (EC) 648/2004 on detergents. Data to support this assertion are held at the disposal of the competent authorities of the Member-States and will be made available to them, at their direct request or at the request of a detergent manufacturer.”

  13. (continue)Check of the biodegradability of surfactants In case that no data are available or verification of the data is required we –as Competent Authority- contact by written procedure (e-mail, letter etc.) the producer of the surfactant and request for additional information, i.e. • valid data which prove that the surfactant fulfills the criteria of Annex III of the Regulation and / or • submission of the corresponding test report.

  14. (continue)Check of the biodegradability of products If there exists an MSDS of the product and the product contains surfactants check: • point 12 “ECOLOGICAL INFORMATION” or • point 16 “OTHER INFORMATION” and follow the steps previously mentioned

  15. Check of the composition and physicochemical properties of the product • Crosscheck in the MSDS of the product (if there exists one) the coherence of the following: • Point 2“HAZARD IDENTIFICATION” • Point 3“COMPOSITION / INFORMATION ON INGREDIENTS” • Point 9“PHYSICAL AND CHEMICAL PROPERTIES” • Point 15 “REGULATORY INFORMATION”

  16. Check of the composition and physicochemical properties of the product Why ? Because : • point 2 presents the hazard of the product, i.e. whether it is classified or not as dangerous. (see for details Reg. (EC)1907/2006 – Annex II – point 2) • point 3 mentions substances presenting health or environmental hazard within the meaning of Directive 99/45/EC (see for details Reg. (EC)1907/2006 – Annex II – point 3) • point 9 focuses on the pH, the flash point etc. (see for details Reg. (EC)1907/2006 – Annex II – point 9) • point 15 presents the labelling of the product (see for details Reg. (EC)1907/2006–Annex II – point 15)

  17. Check of the classification and labeling of the product • Based on: • the exact % w/w composition of the product • the physicochemical parameters and • the classification and labelling rules of Directives 67/548/EEC and 99/45/EC conclude on: • the classification and • the label of the product.

  18. Registry of cleaning products • What is the Registry ? It is a catalogue of all the cleaning products circulated into the Greek market and fulfilling the provisions of the Regulation.

  19. (continue)Registry of cleaning products • Which is the aim of the Registry ? 1st support of the manufacturers by consultation during registration through precautionary check of the data for the products, aiming to the compliance with the Legislation, prior to the product circulation in the market.

  20. (continue)Registry of cleaning products • Which is the aim of the Registry ? 2nd support of the Authorities for: • market surveillance • external border controls

  21. (continue)Registry of cleaning products • Which are the data to submit ? - commercial data - chemical data - other relevant data Confidentiality is legally binding to be kept, where appropriate

  22. (continue)Registry of cleaning products • What is done with these data ? the coherence of all the data is checked and based on them, it is checked the product’s compliance (composition, biodegradability, label) with the provisions of the Legislation (Reg. 648/2004, dir. 99/45 and 67/548).

  23. INSPECTIONS at production / packagingstorage / distribution premises and retailers • Inspectionsare performed under: • annual routine inspection programme • other special reasons

  24. (continue)INSPECTIONS at production / packagingstorage / distribution premises and retailers • Tools employed: • Specialized inspection documents (i.e. letters for the announcement of inspection, inspection forms, model forms for the results of the inspection, calls for explanations in case of infringements etc.) • Data from the “Registry of Cleaning Products” • Relevant Legislation & ISO 17020 (i.e. Reg.(EC) 648/2004, Dir. 99/45 and 67/548).

  25. Sampling of products from the market During surveillance activities of the market, samples of products are taken and submitted to laboratory analysis.

  26. (continue) Sampling of products from the market The results of the analysis are used to verify whether the product (composition, biodegradability, label) complies with the provisions of the Regulation and the data declared to the Registry are consistent with the results.

  27. Controls at the Customsfor conformity with the Regulation During imports of surfactants and/or cleaning products from third countries, Customs Authorities check the coherenceof: • The documents: shipping documents, invoice, import declaration • The product, its label and MSDS, as presented at import. • In case of non-conformity the products are recalled or withdrawn.

  28. VāmulţumescfoartemultThank you for your attention Sophia Antoniadou – PhD Chemist E-mail: gxk-industrial@ath.forthnet.gr

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