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• Registration of chemical substances under REACH Regulation started 1 December 2008. Registration is a final mandatory requirement for companies wanted to continue manufacture and market their chemical substances in the European market and must be completed within a period of three and half, six or eleven years, depending on the tonnage and characteristics of the substances. The staggered deadlines for registration are:

• • 30 November 2010: for carcinogens, mutagens and reprotoxins, in quantities of one tonne per year or more; very toxic substances for aquatic organisms and in quantities of 100 tonnes per year or more; all substances manufactured or imported in quantities of 1,000 tonnes per year or more;

  • 31 May 2013: all substances manufactured or imported in quantities of 100 tonnes per year or more; and

  • 31 May 2018: all substances manufactured or imported in quantities of one tonne per year or more.

• Registration process has impacts on exports of palm oil, palm kernel oil and their oleochemicals which are required to be registered with the European Chemical Agency (ECHA) and this may involve companies to provide lab testing results. Under this regulation, palm based and palm kernel based methyl esters are required to be registered. However, coconut based methyl ester, which has similar properties has been excluded. Malaysia is of the views that coconut based methyl ester share similar chemical composition with palm and palm kernel based methyl ester. As such, palm and palm kernel based methyl ester should be accorded similar treatment under the Regulation.

• Problems faced by Malaysian SMEs in complying with the requirements in REACH include:

  • high cost for testing of the chemical substances especially for flammability, toxicology and ecotoxicology; and

  • lack of understanding on the technical part of REACH regulation.

• Measures undertaken by MITI to address issues on REACH include:

  • setting up of National Steering Committee for REACH implementation, a joint committee co-chaired by MITI and Chemical Industry Council of Malaysia (CICM), The committee consists of related Government agencies and industry associations which have interest in export to EU;

  • Establishment of Technical Working Group Committee, chaired by MITI with members from Government Agencies as well as industry associations.

  • Posting of REACH pre-registration tagline to alert all Malaysian Exporters to EU on the web sites of MITI, MIDA, MATRADE and SMIDEC;

  • Public Announcement: An Advertorial entitled: Industry’s Compliance to REACH-New European Union Chemical Regulation “No Registration, No Market” in the New Straits Times on 9/6/08;

  • A series of workshops and seminars to provide chemicals and chemicals related products industries specific guidance on REACH and to provide a forum for the chemical industry to provide views and comments on the direction of REACH implementation in Malaysia, as follows:

    • 19 June 2008 (MIDA Hall, Kuala Lumpur)

    • 2 July 2008 (MPC Hall, Penang)

    • 9 July 2008 (MPC Hall, Johor Bahru)

    • 16 June 2009 (MIDA Hall, Kuala Lumpur)

    • 30 April 2010 (MITI, Kuala Lumpur)

  • Awareness activities undertaken by CICM to comply with REACH:

    • Promoting awareness on REACH through newspaper advertorial, workshops and seminars conducted throughout Malaysia;

    • Continuing dialogues with the Only Representatives (OR);

    • CICM has made arrangements with REACHLAW LTD. to offer pre-registration and registration services at a discounted rate to Malaysian companies.

    • Presenting a paper on REACH and The Chemical Industry in Malaysia at the Asia Conference on REACH in Shanghai, China on 15 & 16 September 2009.

    • Capacity building programmes related to REACH:

    • Preparation of Chemical Safety Report (CSR) and Chemical Safety Assessment (CSA) for compliance with REACH.

    • Awareness programmes on risk report analysis in relation to REACH.
      

    • Seminars, workshops, road shows, on SIEF and Consortia /CSA/CSR/Registration Dossier.

    • Invited a REACH expert from the UK to speak at two-day workshops in KL and Penang in October or November 2009.