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Dear Readers,

I am proud to present to you Issue 2/2019 of ICRL and particularly pleased to note the inclusion of a special Foreword by ECHA Executive Director Bjorn Hansen. Highlighting the importance of REACH, cross-legislative and cross-agency interfaces and the ongoing discussion of the circular economy, Mr Hansen’s contribution provides a fascinating insight into which areas ECHA sees as a priority in the near future.

With the international political climate becoming more and more challenging and with trade barriers being erected, it is more important than ever to closely monitor global legislative and political activity. With that in mind, ICRL 2/2019 includes contributions on the latest developments in chemical regulation from key jurisdictions: China, the US, Turkey, Switzerland and the EU.

The lead article of this issue addresses the authorisation scheme for biocidal products in Switzerland. Although the Swiss Ordinance on Biocidal Products is technically equivalent to the EU Biodical Products Regulation, some compliance challenges remain. Along with detailing the different pieces of relevant Swiss legislation, Dag Kappes and Brunhilde Kolp Buchs, precisely analyse their respective benefits and burdens.

In their first contribution to ICRL, Maren Rectanus and Doris Peters delve into global data sharing and how it is impacted by the international regulatory environment. The authors not only examine the opportunities and risks of global data sharing but also look at how these process will develop in the future.

In her report about the Chinese regulatory landscape, Siming Sun gives practical advice as regards the implementation of the GHS system (which is not harmonized with EU CLP) and the notification of new chemicals and the data requirements. As the reader learns, some Chinese particularities need to be considered during the notification process.

From China we jump to the USA where Lynn Bergeson draws attention to the evolving challenge of protecting confidential business information (CBI) in light of EPA regulations following the enactment of the Frank R. Lautenberg Chemical Safety for the 21st Century Act. As well as discussing key CBI initiatives, this report provides analysis of the stakeholder community’s response to them.

Rounding off the report section, Yaprak Yuzak Kucukvar looks at ‘Turkish REACH’ (KKDIK) and outlines the most important aspects of the pre-registration phase for manufactured and imported chemicals in Turkey. Besides providing interesting details about the process, Kucukvar points out why a global supply chain perspective is necessary.

Closing the issue we have included a comprehensive case note by Marcus Navin-Jones who gives a valuable overview of two recent court judgments concerning different authorisations under REACH: T-837/16, Sweden v European Commission, and T-108/17 Client Earth v European Commission. Navin-Jones concisely elaborates five lessons to learn for future REACH authorisation applications and demonstrates that the Aarhus-Regulation (EC Regulation No. 1367/2006) might become a new ‘tool’ for data requests.

I hope you enjoy this issue and as always you are very welcome to submit your feedback.

Tobias Schulz

Managing Editor


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