REACH

“REACh” is the Registration Evaluation Authorisation and restriction of Chemicals, 2006, as amended. REACH is the first directly-acting EU regulation to be implemented, which means that it comes into effect across the EU without the need to be implemented by individual national laws.

REACH requires that all existing chemicals placed on the EU market are registered, along with their uses. REACH also supersedes the Notification of New Substances directive (NONS), meaning that new substances on the EU marketplace come under REACH too.

The legal requirement to register is placed on the company manufacturing (by reaction), or importing the substance.

REACH also includes the requirement for the European Chemicals Agency, ECHA, to evaluate the risks from certain chemicals considered to be the most hazardous. If these chemicals are found to be particularly hazardous, ECHA is required to control their supply and use very tightly with a view to removing them from the EU market altogether, the “authorisation and restriction” part of REACH. These chemicals are called SVHCs, Substances of Very High Concern.

The main obligation for manufacturers and importers under REACH is to register chemicals with ECHA on a phase-in timescale depending on the hazardous nature of the chemical, and the tonnages made or imported into the EU as follows:

Date	Substances required to be registered:
1^st December 2010	> 1 tonne per annum, Cat 1 or Cat 2 Carcinogens, Mutagens or Reprotoxins > 100 tonnes per annum, Very Toxic to Aquatic Environment > 1,000 tonnes per annum, other substances
1^st June 2013	100 – 1,000 tonnes per annum, other substances
1^st June 2015	10 – 100 tonnes per annum, other substances 1 – 10 tonnes per annum, other substances

Date

Substances required to be registered:

1^st December 2010

> 1 tonne per annum, Cat 1 or Cat 2 Carcinogens, Mutagens or Reprotoxins
> 100 tonnes per annum, Very Toxic to Aquatic Environment
> 1,000 tonnes per annum, other substances

1^st June 2013

100 – 1,000 tonnes per annum, other substances

1^st June 2015

10 – 100 tonnes per annum, other substances

1 – 10 tonnes per annum, other substances

Any chemical which is made or imported at > 1 tonne per annum quantity and which is due to be registered in 2018, should be pre-registered by the manufacturer or importer using the REACH-IT system at ECHA. Where pre-registration is not appropriate, a substance becomes liable for immediate registration.

There are extra obligations on manufacturers and importers where a substance is classed as an SVHC, including extra information required on the label and SDS, and a further restriction on the uses allowed. In some cases, an SVHC may be banned completely from being placed on the EU market.

REACH also requires downstream users of chemicals, to ensure that their uses are registered under the regulation. If the use is not registered, it is not legal to use that chemical for that purpose, although there is the possibility to register your use separately at ECHA.

REACH is a major task for many companies in the chemical supply chain, and registration, in particular, can be very costly and time consuming.

We can provide help with:

REACH peer support through the Chemical Regulations Self Help Group
REACH cost sharing for Member Registrants
REACH tonnage band calculations
REACH cost sharing for Lead Registrants
REACH consultancy, including assessing your REACH liability, help with pre-registration, understanding REACH requirements etc, see Support Contracts, or contact us for details, email Janet.

As we are not toxicologists, we do not currently offer help with certain technical aspects of REACH such as compiling REACH dossiers, but we do know several reputable consultants who carry out this type of work, so feel free to ring us for a chat.

If you need help with REACH, contact Janet on 01422 24 22 22, or email us.