Industrial Chemicals Registration Law Proposal Published for Public Commenting

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Industrial Chemicals Registration Law Proposal Published for Public Commenting

Dear Clients and Colleagues,

The proposal of the Industrial Chemicals Registration Law was composed as part of Israel’s commitments to the OECD to establish a national mechanism for chemical registration. The mechanism is designed to protect human health and the environment from harmful effects of chemicals, by collecting information about chemicals and making it available to the public.

Although there is extensive regulation in Israel which regulates numerous chemical practices, the Ministry of Environmental Protection believes that the existing regulation is decentralized and leaves aspects concerning the environmental and health risks of chemicals unanswered.

The law proposed by the Ministry of Environmental Protection will apply to manufacturers and importers of chemicals and chemical mixtures and obligate them to collect and hold information regarding the properties and risk factors of the chemicals to the environment and human health.

The proposed mechanism for collecting information about the chemical and managing its risk consists of three main steps:

Step I – Establishing a chemical database: The database will be created based on reports submitted by the industry regarding chemicals manufactured in Israel or imported into Israel, at this stage in quantities exceeding 10 tonnes per year. This database will be public and include the chemical properties, quantities and uses for which it is intended.

Step II – Assessing chemical risks: Out of all of the chemicals listed in the database, certain chemicals will be chosen for mandatory risk and potential exposure assessments. If there is existing information regarding these chemicals in public databases established under corresponding regulation around the world, an abbreviated assessment of the chemical risks will be conducted according to existing information.

Step III – Formulating a recommendation for chemical risk management: According to the findings of the risk assessment phase, a committee comprised of representatives of regulators, the industry and environmental organizations will determine prohibitions or limitations on the use of the particular chemical (in its manufacturing, usage and disposal process) to minimize the risk of exposure to it. These prohibitions and limitations may also apply to chemicals that are or may be found in products and articles.
The enforcement measures proposed in the proposal are administrative measures, i.e., enforcement notices and financial sanctions.

The schedules set for the approval and implementation of the proposed legislation are tight: the proposed date of entry into force is 1.3.2023 (one year after the scheduled approval date). From this date, manufactures and importers will have a year and a half to report existing chemicals in their operations, meaning the chemical database is expected to be established by 1.9.2024. If these deadlines are met as planned, the chemical risk assessment and management phases will begin during the year 2025.

The proposal is open for public comments until 22.10.2020.

The Environmental and Industrial Manufacturing Department has been representing manufacturers, exporters and importers operating in Israel and abroad in the field of chemicals and products containing chemicals, including entities subject to REACH regulation, for over a decade and advises them in these contexts. The department’s team takes part in the joint industry and Ministry of Environmental Protection committee to formulate the outline of the law.

Considering the method of entry into force and the expedited implementation proposed by the Ministry of Environmental Protection in the proposal of the law, an examination of the applicability of the proposed law and identification of the possible interfaces with your operations in its planned outline is recommended.

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We are here to offer any assistance and advice in relation to questions or clarifications that may be required, also during the period of lockdown.

Sincerely,
The Environmental and Industrial Manufacturing Department

Herzog Fox & Neeman