Highlights from November Forum meeting

Purpose

The Enforcement Forum meeting held in November 2024 aimed to revise the work programme, outline enforcement priorities for 2025, and initiate new enforcement projects. The revised work programme focuses on controlling imports, online sales, classification, and labelling requirements for mixtures, including biocides. This update is essential for industry stakeholders as it sets the direction for future enforcement efforts.

The Enforcement Forum meeting also aimed to finalize preparations for the next EU-wide harmonized enforcement project (REF-14), which will focus on classifying and labeling hazardous mixtures, including those found in consumer products like electronic cigarettes or air fresheners. Additionally, preparatory work began for a pilot project monitoring the compliance of only representatives who register imported substances.

Effects on Industry

The revised work programme and new enforcement projects are expected to have significant effects on industry stakeholders. The focus on controlling imports, online sales, classification, and labelling requirements for mixtures, including biocides, will likely lead to increased scrutiny and potential enforcement actions against companies that fail to comply with these regulations.

The initiation of the REF-14 project will also impact industries that produce or distribute hazardous mixtures, as they will need to ensure compliance with the new classification and labeling requirements. The pilot project on monitoring only representatives who register imported substances may lead to increased transparency and accountability in the importation process, potentially affecting companies that rely heavily on imports.

Relevant Stakeholders

The revised work programme and new enforcement projects affect various stakeholders, including:

• Importers and exporters of goods, particularly those related to chemicals and biocides
• Online sellers and e-commerce platforms
• Manufacturers of hazardous mixtures and consumer products like electronic cigarettes or air fresheners
• Only representatives who register imported substances
• Companies that rely heavily on imports

Next Steps

Industry stakeholders must take the following actions in response to the revised work programme and new enforcement projects:

1. Review and ensure compliance with the revised classification and labeling requirements for mixtures, including biocides.
2. Prepare for increased scrutiny and potential enforcement actions related to imports, online sales, and compliance with regulations.
3. Engage with regulatory bodies and ECHA to understand the implications of the REF-14 project on their businesses.
4. Participate in training sessions and workshops provided by BPRS and other relevant organizations to stay informed about emerging topics and harmonized enforcement practices.

Any Other Relevant Information

Additional information that may be helpful to stakeholders includes:

• The Enforcement Forum meeting is a biennial event, with the next meeting scheduled for March 2025.
• The revised work programme will soon be published on ECHA’s website, providing further details on the focus areas and priorities for 2025.
• BPRS has initiated preparation of training sessions for BPR inspectors in 2025, which may be beneficial for industry stakeholders to ensure compliance with regulations.