REACH 2006 / 1907

The main aims of REACH are to:

• Improve the protection of human health and the environment from the risks that can be posed by chemicals
• Enhance the competitiveness of the EU chemicals industry, a key sector for the economy of the EU
• Promote alternative methods for the assessment of hazards of substances
• Ensure the free circulation of substances on the internal market of the European Union

Who does it apply to?

REACH applies to substances manufactured in, or imported into the EU in annual quantities of 1 ton or more.

What is required of me?

REACH gives requirements for substances themselves, in preparations, or intended to be released from an article. These substances may be required to be registered, notified, authorized, subject to classification and labeling, subject to restrictions, or a combination of the above. It can be difficult and complex to determine where the substances you deal with fall under REACH.
Registration

Most of the substances that fall under REACH are subject to registration. Registration of these substances includes submitting a vast technical dossier with information on the substance and its uses to the European Chemicals Agency (ECHA). Click here for further information on articles under REACH.

Phase In Substances

Many manufacturers and importers are currently circulating substances which are required to comply with REACH. These substances are referred to as “Phase In” substances, or “existing substances.” REACH provides a transition regime for these substances to comply with the regulation.

REACH Process for Phase-In Substances

1. Identify the substances you work with which are required to be compliant under REACH
2. Pre-Registration (June 1, 2008-Dec 1, 2008) Pre-Registration is offered for phase in substances to assist in the transition and implementation of this regulation. While this process is not required, it is highly recommended and will save unnecessary complications in the future. Phase In substances that are pre-registered are allowed extended registration deadlines and do not have to remove substances from the market before they are fully registered.
3. SIEF Participation After pre-registration is complete in December, the ECHA will post the information on their database. Following, a Substance Information Exchange Forum (SIEF) will be formed for different companies who have the same substances and the same uses. This includes a joint submission of data, allowing groups to work together to find the required information on the substances and will lessen the amount of testing on vertebrate animals. The aims of the SIEF are to:
   • Facilitate data sharing for the purposes of registration
   • Agree on the classification and labeling of substances concerned
   • May be a starting point for organization for the joint submission of data
4. Registration: The actual registration dates for substances will vary from 2010-2018 depending on the quantity and risks of the substance. Registration will be submitted jointly for SIEF groups who have completed and compiled the required data.

Non Phase In substances will be required to go through the registration process, though the timelines and requirements which are applicable differ. Please contact us for more information.

It is vital to your company to appoint an Only Representative for this process (for both EU and non-EU manufacturers).

A Third Party Representative is also an option for manufacturers.

European “Green” Directives and Regulation, like REACH, are becoming prevalent and crucial points of interest for anyone involved in placing products on the European market. A comprehensive Environmental Strategy is necessary to study and satisfy the requirements you are constrained to abide by.

Not sure if you need to comply? Contact us

Last updated Apr 22, 2009

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