The flavor and spice products exported to the EU are generally classified into natural spices (such as clove oil, peppermint oil, etc.) and synthetic perfume products (such as benzene, ethanol, eugenol, vanillin, etc.).

 

The definition of flavor and fragrance products in REACH is the category of 'matter' or 'product'. According to the REACH regulations, China's flavor and fragrance enterprises need to appoint a professional and reliable "sole representative" to fulfill the relevant responsibilities of the EU REACH regulations. The responsibilities of flavors and fragrances in REACH are pre registration, information transfer, authorization and restriction in supply chain.

 

The general steps for flavor and fragrance enterprises to deal with EU REACH regulations are as follows:

 

1. List the trade products of enterprises to the EU;

 

2. According to the reach regulation registration guide and the substance naming and Identification Guide (see www.reach. Gov.cn), calculate the tonnage of the substance exported by the enterprise to the EU;

 

3. List of all substances exported to the EU equal to or greater than 1 ton / year;

 

4. List all substances that need to fulfill reach obligations according to the application scope of REACH regulations;

 

5. Collect the information (identification of substances, spectrum information) of the substances subject to reach regulations;

 

6. Look for a professional and reliable 'sole agent' to register the reach of the substance.

 

Due to the specialty of flavors and fragrances, the essence and flavor enterprises should pay attention to the following matters in dealing with the EU REACH regulations.

 

The first is the identification of matter. In the EU REACH regulation, substances are divided into single component substances, multi-component substances and other types according to the information of composition and content. Different from other chemical products, many flavor products are not simple single component substances, but also contain isomeric substances similar to the main component substances, and the content is very high (in some cases, more than 20%). At this time, we can't simply regard this flavor product as a single component substance, but as a multi-component substance for reach registration. In particular, if the enterprise fails to submit the materials in the correct category during pre registration, it may not enjoy the registration buffer period of phased materials.

 

Secondly, some of the flavor and flavor products are natural spices, that is, products are obtained through natural extraction. In the EU REACH regulation, 'naturally occurring substances' are exempt from reach registration as long as they are not defined as' dangerous goods' in accordance with the relevant EU regulations. So does' natural flavor 'need reach registration? On April 9, 2008, the European Union Chemical Administration (ECHA) provided a detailed answer to the registration of' naturally produced substances' in its updated FAQ. In the FAQ of ECHA, it is pointed out that 'naturally occurring substances' have their own detailed definitions in the EU REACH regulations, and only in strict compliance with the definitions in the EU REACH regulations can they enjoy the obligation of exemption from reach registration. And 'natural flavor' only means that the product is not artificially synthesized, but extracted from natural products. The vast majority of 'natural flavors' do not meet the definition of' naturally occurring substances' in REACH regulations, i.e. they cannot be exempted from reach registration.

 

In order to avoid the impact of EU REACH regulations, experts from the China Inspection and quarantine REACH solution center strongly recommend that the flavor and fragrance enterprises analyze their products exported to the EU as soon as possible, and entrust the sole agent for registration. For natural flavor products, it is necessary to compare the product information and production process information with the relevant provisions of the EU REACH regulation to see whether they conform to the 'naturally produced substances', so as to determine the obligations under the EU REACH regulation.