EHS Management

Enforcement of Trending Global Regs

EU Vehemently Targeting Lead

Lead is not only an environmental problem when handling the waste, but also poses health risks for consumers and those working in the manufacturing industry and in waste management.
According to the EU, 23 percent of EEE tested contain excessive levels of lead. As such, the EU has stated its intent to strengthen enforcement throughout Europe.

REACH enforcement is proceeding particularly well.

  • REACH Enforcement-I project in 2009 and 2010-2011 inspected some 2,400 companies on REACH registrations and safety data sheets (SDS)
  • Altogether noncompliance was observed in 24 of inspected companies.
  • For 42 percent of the chemicals checked, there was either no SDS or an inappropriate SDS.
  • REACH Enforcement-II project in 2011-2012, began in April 2011. Specifically, the EU inspectors will control the supply-chain related obligations for substances in the mixtures prepared by formulators (paints, cleaning products, lubricants, plant protection products, etc), as well as the classification, labeling, and packaging (CLP) notification requirements. They will also check if the substances placed on the market in mixtures are registered or pre-registered. In addition, the inspectors will raise awareness of the future obligations for Downstream Users. This enforcement focus on mixtures will likely see a larger impact on importers and Only Representatives to make certain they are fulfilling their functions.

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Why Should You Care?

Companies should care because there is a new world of enforcement in today’s dog-eat-dog world. It’s not just the inspectors that you should concern yourself with. Your competitors, consumer protection organizations, and even industry associations have been playing a big role in tattling on noncompliant companies. Remember these reports?


  • Pre-Christmas seizure of 1.3 million PlayStations ($229 million) by Dutch police
  • Cadmium in cables exceeded Dutch limits
  • Most likely ratted out by competitor

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  • 3 recalls because lead-based paint exceeded U.S. limits
  • Chinese toy-maker went out of business after owner’s suicide
  • Company fined $2.3 million by Consumer Protection Safety Commission

European Tyre and Rubber Manufacturers’ Association


  • On October 17, 2011, ETRMA announced that 10 percent of the tires tested are noncompliant and should be withdrawn from the market.
  • ETRMA is concerned that European surveillance efforts have not been sufficient to prevent these tires from entering the European market and have effectively made it possible for European importers to continue selling illegal tires.

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