Speciality Chemicals Magazine MAY / JUN 2022 | Page 69

REGULATION & COMPLIANCE formally defined ; it is expected to follow REACH but that is not certain . Information submitted for registration will be treated as confidential , with some exceptions , if it is a trade secret , though exactly how this will work is not yet clear . As of 9 August 2022 , the GHS will enter into force in Israel after a threeyear transition period . This is the direct result , Wenk said , of a decision by the OECD in 2018 that member states are required to implement the GHS in a timely manner . The regulation is broken down into two parts ( GHS SI 2302 , Parts 1 and 2 ), focusing respectively on classification , labelling , marking and packaging of dangerous substances and mixtures , and transportation , respectively . Shimshon Roth , a regulatory and compliance analyst at Enhesa , also focused on recent regulatory developments in Israel . He noted that Israel ’ s GHS SI 2302 uses the same classification as Annex I of the CLP as amended in 2018 , but is narrower in scope . Excluded from it are :
• Transportation of dangerous goods
• Drugs
• Pest control products ( unlike the EU CLP )
• Plant protection products ( unlike the EU CLP )
• Veterinary preparations
• Cosmetics
• Radioactive materials
• Gas cylinders
• Hazardous waste
• Storage in bulk
New import regulations will drastically affect regulation in Israel
Tactile warnings are required on food and beverage products intended for use by the general public and classified to categories specified in CLP Annex II Part 3 . Unlike the latter , it excludes aerosol dispensers classified flammable or extremely flammable . The technical specifications must conform to ISO 11683 . There are also specific requirements for child-resistant fastenings and liquid consumer laundry detergents in soluble packaging , all based on the criteria specified in CLP Annex II Part 3 .
Import changes
Far more significant than any of the changes in GHS implementation , though as yet less well defined , is Israel ’ s current import reform proposals . “ This is a revolution in the making . It is a dramatic change in import policy with implications for a large number of regulatory instruments and consequently imported products ,” Roth said . The legal basis of this is the Economic Plan ( Arrangements Law ) for the years 2021-2022 , which will be published on 18 November 2022 . This law specifies recognised legislation in other countries , most obviously the EU and the US , though others will be added . Complying with the requirements in these countries may be enough for many product types . Currently , the system is based on pre-market licensing and registration by the authorities plus pre-market conformity inspection by the Standards Institute . Under the reform , Israel will move to a system of importers ’ declarations of conformity and notification , with post-market surveillance by the authorities . “ Israel is not obliged to harmonise its legislation with any region ,” said Roth . “ Consequently , Israeli regulation is unique to Israel and is perceived by many as a trade barrier . The new reform makes legislation and standards in recognised counties acceptable in Israel .” Labelling language requirements will not change , however . According to the latest information from the authorities , Roth said , different product types will have specific import rules , from licensing to approval based on demonstrating conformity to mandatory standards ( the GHS in the case of chemicals ). Guidance will be provided to importers and the same options will apply to local producers . There may be more legislation to come . Using cosmetics as an example , from 1 January 2023 there will be a register of importers who will not require a licence . They will make a simple declaration of conformity and notification and products meeting the requirements of the EU Cosmetic Products Regulation ( 1223 / 2009 ) will be deemed to have met the Israeli assessment requirements . In addition , a parallel import route will be established for a long list of cosmetic product types based on a similarity to already approved products . The main exceptions to this are sunscreens and products for babies , children under 12 years , and pregnant or nursing women .
Changes in South Africa
South Africa , said Emel Kasim of Verisk 3E , has the most comprehensive set of chemical regulations in Africa , managed by many different government departments . The most significant recent development has been the Regulations for Hazardous Chemical Agents , promulgated under
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