In addition to registration, you should also be concerned about the development direction of REACH after 2018. With the development of EU REACH after 2018, the European Chemicals Agency (ECHA) will require operators to maintain registration updates, and will continue to conduct substance assessment and inquiry, authorization and restriction, and implement CLP Audit work such as specifications and safety data sheets. As a finished product supplier, you may be faced with finished product registration, notification or supply chain communication obligations. In July 2013, REACH enforcement agencies (including Belgium, Denmark, France, Germany, Norway, and Sweden) announced the compliance guidelines for substances of high concern in finished products (Guidance for Suppliers of Articles). In terms of supply chain communication, it is recommended that if the finished product contains SVHC > 0.1% (w/w), the industry should provide consistent information whether it is a separately sold finished product or an assembled finished product. And if the assembled finished product contains SVHC, the information content should include where the SVHC substance is contained, and the information should be communicated concisely among the supply chain. It is worth noting that on September 10, 2015, the European Court of Justice ruled that individual finished parts should be used as the basis for calculating SVHC 0.1% (W/W). Taking shirts as an example, the SVHC content of the shirt's textile fabric, buttons, and sewing threads will be calculated separately, instead of using a single shirt as the calculation unit. In order to comply with the requirements for information communication between REACH supply chains, it is recommended that enterprises analyze the information provided by suppliers and grasp the following principles:

12 new substances were added to the EU REACH authorization list. Industry regulations are in good compliance. In 2017, 12 new substances were added to the EU REACH authorization list. The European Commission added them based on the recommendations of the fifth and sixth appendix 14 of ECHA. Currently, appendix 14 There are a total of 43 listed authorized substances. After the sunset period, substances on the list can only be used within the EU after authorization. If manufacturers want to continue to use these authorized substances after the sunset period, they will need to apply for authorization before the deadline. For detailed application authorization periods, please refer to the details on the ECHA official website in the reference material. Project Chinese name English name EC number CAS number 32 1-Bromopropane 203-445-0 106-94-5 33 Diisopentylphthalate 210-088-4 605-50-5 34 1, 2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters, C7 rich 276-158-1 71888-89-6 35 1,2- 1,2-Benzenedicarboxylic acid, di-C7-

A new REACH Appendix 17 Q&A was added to the EU website to help answer industry questions. On June 7, 2017, the European Chemicals Agency announced that it would work with the European Commission on Annex XVII of the Registration, Evaluation, Authorization and Restriction of Chemicals Regulations (REACH Regulation). new guidance in a question-and-answer format. The purpose of restrictive measures is to protect human health and the environment from unacceptable risks arising from exposure to chemicals. Restrictions apply to substances existing on their own as well as in mixtures or articles, including substances that do not require registration. Merchants must note that these restrictions apply to both EU-made and imported goods. The guidelines are published in a question-and-answer format and are intended to assist relevant industries and also assist law enforcement agencies in implementing relevant restrictions in all member states. According to the Q&A content, multiple items in Annex XVII (items 5, 31, 43, 50, 51 and 52) are all related to toys. However, the "REACH Regulation" does not define the meaning of "toys". According to the European Union's Toy Safety Directive (Directive 2009/48/EC), a toy is defined as "a product designed or intended for use by children under 14 years of age in play (whether or not specifically intended for their use)." The "Directive" has provided a detailed list in Annex I, specifying what products do not fall into the category of toys (such as folk dolls and decorative dolls, or puzzles with more than 500 pieces). In addition, some products clearly listed as not belonging to the category of toys include toy cars equipped with internal combustion engines, toy steam engines, ejector and catapults.

UEAPME criticized the REACH guidelines for being unable to help small and medium-sized enterprises comply with their obligations on SVHC in finished products. Last month, the European Chemical Agency (ECHA) issued an updated guidance (Guidance on requirements for substances in articles) to assist manufacturers in understanding if finished products contain high levels of SVHC. Substances of concern (SVHC), in order to comply with the requirements of REACH regulations, manufacturers must prepare information and respond. The European Association of Craft, Small and Medium-sized Enterprises (UEAPME) pointed out that the case studies cited in the guidelines published by ECHA are not of substantial help to small and medium-sized enterprises. In 2015, ECHA ruled that when identifying whether the SVHC content in a finished product exceeds 0.11% by weight of TP3T, the definition of the finished product must be uniformly standardized within the EU, thus interpreting the finished product. The single entities contained and composed of an article are regarded as finished products under the REACH regulations. Therefore, in a relatively complex product, its numerous components will be regarded as individual finished products. Therefore, component suppliers are also given the responsibility to communicate SVHC information in the REACH regulations. For REACH Regulation 7(2), the SVHC content in the finished product exceeds 0.1%

2017年7月歐盟REACH正式公告174項高度關切物質 歐洲化學總署(ECHA) 2017年7月7日公告新增1項高度關切物質，使得高度關切物質總數來到174項。 「全氟已-1-磺酸及其鹽類」(Perfluorohexane-1-sulphonic acid and its salts，PFHxS)是一種全氟及多氟烷基物質(per- and polyfluoroalkyl substances， PFAS)類阻燃劑，使用於塑化劑、界面活性劑及防火泡沫中，因為「非常持久性和非常生物蓄積性(vPvB)」的特性而列入高度關切物質清單。 同時歐盟化學總署也調整清單中特定物質列入SVHC的原因，加入環境荷爾蒙的分類依據，包括鄰苯二甲酸二(2-乙基已基)酯(DEHP)、鄰苯二甲酸丁酯苯甲酯(BBP)、鄰苯二甲酸二丁酯(DBP)、鄰苯二甲酸二異丁酯(DIBP)及雙酚A等5項物質。 業者應特別注意歐盟REACH的成品通報與供應鏈溝通規定。 通報規定適用條件： 1. 物質是可能列入授權的高度關切物質 (第57條)；且 2. 個別製造商或進口商成品中的成品中高度關切物質年總量超過1噸；且 3. 高度關切物