global environmental legislation guide - National Marine ...

Issues for the recreational marine and superyacht industriesAlthough REACH gives greater responsibility to the industry, it is at the same time morecomplicated to comply with and import, manufacture or use products/substances withinREACH.First EU REACH deadlineThe first EU REACH registration deadline was 1 December 2010. A total of 4,300 substanceswere registered with the European Chemicals Agency. Switzerland has incorporated the EUCLP regulation through the amended ordinance of 10 November 2010 of the protectionagainst hazardous substances.The EU is currently working on Nano Inventory from REACH.REACH Fact SheetThe ICOMIA Environment Manager will draft a fact sheet aimed to the recreational marineand superyacht industries.REACH reinforces communication obligations along the supply chain betweenmanufacturers, importers of substances and downstream users. Downstream users may beformulators of preparations (e.g., the paint industry). The European Commission considersthem being “first level downstream users”. Other industries, however, represent “secondlevel” downstream users, meaning that these industries mainly use but do not producesubstances or preparations in their engineering processes.E.g., the second level downstream industries use oils, lubricants, inks, glues, metals, alloysand plastics when producing articles. Most companies, yards and marinas within therecreational marine and superyacht industries are considered being a “second leveldownstream users”.To give the industry more detailed information in order to define what their responsibilitiesare regarding REACH, ICOMIA EE drafted a comprehensive fact sheet aimed to therecreational marine and superyacht industries with the integration of the latest progress anddevelopments of REACH.10. Rules For Timber Certification to Halt Deforestation, (see Lacey Act inUSA); Regulation EU - 995/2010 (20 October 2010)The European Parliament and European Council have approved the legislation whichprohibits the sale of timber logged illegally under the rules of the country of origin. Inaddition to this, companies must use a system of 'due diligence' to ascertain that the timberthey sell in the EU was harvested legally. It was published in the EU under the name of“FLEGT Action plan” and in the US as the “Lacey Act”.The FLEGT Action Plan contained commitments to examine domestic legislation in EUmember states, to analyse whether it could allow action against imports of illegal timber,and to examine options for additional legislation, should existing domestic legislation proveinadequate. There are documents below which contain studies published on this issue.21