Australia POP

On December 12, 2023, the Australian Government took significant steps by incorporating various substances into their Industrial Chemicals Environmental Management (IChEMS) Register. Notably, adjustments were made to schedules 6 & 7, aimed at phasing out substances such as PBDE, HBCDD, PFOA, and SCCPs. These amendments entail strict prohibitions on importing, exporting, and manufacturing, with some essential use exemptions.

The implemented prohibitions closely mirror the restrictions outlined in the EU POP and EU RoHS regulations, with some nuanced differences. Effective dates for these restrictions vary, with the next milestone set for July 1, 2024.

For further insights on Australia’s POP regulations, please feel free to reach out for additional information.

Maine and Minnesota PFAS Currently Unavoidable Uses Deadlines

As of December 18, 2023, the Minnesota Pollution Control Agency is requesting comments and Currently Unavoidable Uses (CUU) for PFAS. 

As of January 10, 2024, the Maine Department of Environmental Protection is also accepting proposals for CUU of PFAS. 

The deadline for submission in both states is March 1, 2024

These proposals are to form the foundation for PFAS use exemptions, shaping the regulatory landscape for PFAS restrictions in each state. Approvals granted in Maine and Minnesota are expected to enhance the likelihood of obtaining parallel exemptions in other states with similar PFAS legislation, such as California and New York.

Similar to Claigan’s very successful EU PFAS derogation submission project, Claigan is inviting companies to participate in the Maine/Minnesota PFAS exemption project. This campaign will provide companies with the opportunity to ensure their uses are subjected to thorough review. Leveraging extensive information from the EU derogation process, Claigan’s Maine/Minnesota submission project aims to compile a comprehensive and well-supported list of common uses within the demanding deadline of March 1, 2024.

For more information,  get in touch.

Canadian Plastics Registry

On December 30, 2023, the Government of Canada initiated a consultation period for the Federal Plastics Registry, which is set to conclude on February 13, 2024.

The Canadian government is actively developing a registry dedicated to the comprehensive reporting of plastics in the realms of electronics and packaging. This requirement specifically applies to individuals identified as producers of plastic products, encompassing brand owners residing in Canada or the initial resident responsible for manufacturing or importing a plastic product into the country.

This reporting obligation is slated to be an annual process, with the first report due by September 29, 2025. This initial submission will pertain to the 2024 calendar year, necessitating the identification of the resin used in product manufacturing, the resin’s source, the category and subcategory of plastic products, and the total quantity (measured in tonnes) introduced to the Canadian market. In subsequent years, additional details, such as the percentage of plastics collected at the end of their life cycle, those diverted to recycling, re-processed, incinerated, and composted, will be expected.

For more comprehensive information on the Canadian Plastics Registry, please do not hesitate to reach out. Additionally, feel free to explore Claigan’s latest webinar on the Canadian Plastics Registry for additional insights.

Russian Iron and Steel

On Wednesday, January 3, 2024, Claigan Environmental is announcing their consulting services for Russian Iron and Steel. The European Union (EU) and the United Kingdom (UK) have imposed sanctions on iron and steel originating from Russia, effective since September 30, 2023.

The EU and UK are actively seizing shipments of iron and steel lacking proper documentation, leading to supply chain disruptions and leaving companies vulnerable.

Claigan simplifies the process. Our experts can quickly identify high risk suppliers, collect mil-certificates, and provide declarations for your direct customers or customs official.

For more information,  get in touch.

Forced Labour in Canadian Supply Chains

On December 20, 2023, the Canadian Government released new information about reporting requirements for Forced Labor and Child Labor for businesses operating or selling goods in Canada. 

Companies must submit their first report to the Minister of Public Safety Canada by May 31, 2024. These reports should outline the steps taken in the previous financial year to prevent and reduce the risk of forced labor or child labor in supply chains.

For more information,  get in touch.

AB-1200 California Safer Food Packaging & Cookware Act of 2021

In California, cookware manufacturers have been mandated to disclose the chemicals in their products on their websites since January 1, 2023. As of January 1, 2024, new labeling requirements for products will come into effect.

The AB1200 declarable chemicals are a very wide range of chemicals including most metals (ex – iron, copper, nickel), PFAS, phthalates, regulated flame retardants (such as TBBPA), and most other substances regulated in the US (including Prop 65) and the EU.

Claigan, with its proactive approach, has been actively testing and guiding companies through these regulatory shifts. Recognizing the challenges and time constraints in relying on supply chains to declare hazardous chemicals, Claigan offers an efficient solution to test your products, ensuring compliance with labeling obligations.

For more information,  get in touch.

Five (5) New SVHCs (January 2024)

On December 14th, 2023, the Member State Committee (MSC) unanimously approved five (5) new Substances of Very High Concern (SVHCs) and on update to a sixth substance.

New SVHCs
UV-326
UV-329
2,4,6-TTBP
OAPP
2-(dimethylamino)-2-[(4-methylphenyl)methyl]-1-[4-(morpholin-4-yl)phenyl]butan-1-one

Additional property – DBP (endocrine disruptor environment)

The new SVHCs are expected to be officially listed January 23 2024.

PFAS SUBMISSION PROJECT

On Thursday September 21st, 2023, Claigan Environmental submitted the PFAS submission project to ECHA. The project consisted of 5 different submissions (1) PFAS in articles, (2) PFOA in articles, (3) PFAS in drinking water, (4) Comparison of alternatives, and (5) Derogations requested. This project was the culmination of input provided by over 30 companies and included 53 derogations. 

The goal was to provide a multi-industry response to ECHA that accounted for a wide range of necessary PFAS uses and request the respective derogations.

Through Claigan’s expertise and experience, companies across multiple industries ensured that their varied, necessary uses of PFAS were covered by derogations and could continue being used. Companies that did not submit their requests for derogations could find themselves having to make costly material changes to their products to keep selling in the EU.

UYGHUR FORCED LABOR PREVENTION ACT (UFLPA)

Ottawa, 3 January 2023 – Claigan Environmental Inc. is announcing their Uyghur Forced Labor Prevention Act (UFLPA) services. Building from our Conflict Minerals due diligence work, Claigan has identified numerous gold refineries that source from Xinjiang province.

Under UFLPA, US Customs and Border Protection can stop and hold your products if they believe the materials originated from Xinjiang province. To release your products from customs, you need to show due diligence that your products did not benefit from forced labour.

Claigan’s approach to due diligence is proactive and follows the U.S. Customs and Border Protection Operational Guidance for Importers. Claigan’s process is a step wise approach to assessing the risk of each supplier and related due diligence requirements. From that risk assessment and due diligence, Claigan produces an evidence package for each supplier that can be provided to US Customs and Border Protection, or as reference to inquiring customers.

The Uyghur Forced Labor Prevention Act is a United States federal law that changes U.S. policy on China’s Xinjiang Uyghur Autonomous Region with the goal of ensuring that American entities are not funding forced labor among ethnic minorities in the region.

For more information on UFLPA,  get in touch.

Also feel free to watch Claigan most recent webinar on UFLPA here.

PFAS Compliance Service

Ottawa, 20 December 2022 – Claigan Environmental Inc. announcing their perfluoroalkyl substances (PFAS) compliance services. To comply with global PFAS reporting and restriction requirements, Claigan, an ISO 17025 accredited laboratory, has developed a comprehensive and practical approach to PFAS compliance for products. The process was developed to comply with the PFAS reporting requirements for the State of Maine, the PFOA related restrictions in the EU and California, and other emerging requirements in the US, Canada, EU, and Asia.

Fluoropolymers are ubiquitous in consumer, professional, and medical products. Fluoropolymers such as PTFE and FKM provide significant performance advantages in many different applications. Due to political pressures related to some of the residual perfluoroalkyl substances (such as PFOA) in fluoropolymer and fluoro-coatings, an increasing amount of jurisdictions are implementing regulations related to PFAS. Some of these regulations are restrictions. Many are far reaching, mandatory data reporting requirements.

Claigan’s approach consists of practical testing for fluorine by using WDXRF. For products with fluorine, further testing is applied to identify the type of fluoropolymer and and restricted PFAS (such as PFOA). The process relies on the concept: if there’s no fluorine present, then there’s no fluoroalkyl present. If fluorine is present, more refined testing can be conducted to identify the polymer present and test for unintentional residual chemicals such as PFOA (down to 25 ppb).

Claigan’s process is very practical and can be applied on a part by part basis, or used in a survey type approach to create a sufficient enough picture for PFAS reporting.

For more information on PFAS compliance, get in touch.

Also feel free to watch Claigan most recent webinar on PFAS compliance at here.