The REACH or Registration, Evaluation, Authorisation and Restriction of Chemicals regulation was first introduced on June 1, 2007 by the European Chemicals Agency (ECHA).
If you are a manufacturer, importer or end-user of chemicals the word “REACH” would have crossed your path at some point since the inception of the regulation eleven years ago.
However, you may not be fully aware of your responsibilities and obligations in accordance with REACH. At Chemdoc, we understand how difficult it can be to decipher and implement all required aspects of the regulations and have provided you with this guide to ensure you are REACH ready.
The REACH Regulation was introduced as a way of gathering useful information on all chemical substances in the European market. The aim was to create a comprehensive database of all chemicals available in the EU in order to reduce the risk to human health and the environment.
REACH requires all companies who manufacture or import substances in quantities in excess of 1 tonne per annum to complete a registration dossier with ECHA. Since the introduction of the regulations in 2007 there have been many deadlines for companies to register their substances.
These deadlines have been based on the tonnage band of a substance manufactured or imported and the classifications of the substances.
The next and last registration deadline is 31 May 2018 and affects pre-registered substances manufactured or imported from outside the EU in quantities between 1 and 100 tonnes per year which have not been fully registered. If your company has not pre-registered your substances, then this deadline is insignificant to you and you will need to register any substances manufactured or imported in quantities greater than 1 tonne per year before manufacturing or importing. If these are relevant to your company and you have not registered your substances by the 31 May 2018 deadline you will not legally be permitted to import or place chemicals substances on the EU market.
The final deadline is expected to be significantly different to all previous deadlines for the following reasons:
1. The number of registrations is expected to be 60,000. This estimated figure is almost three times larger than any of the previous deadlines. In addition, the number of individual substances expected to be registered is 25,000.
2. The previous deadlines in 2010 and 2013 mainly affected large organisations who manufacture or import substances in quantities greater than 1 tone. This deadline will affect inexperienced and small and medium sized enterprises (SMEs). So far the number of registrations completed is far below the expected figures estimated by the Agency
The registration process has been continuously monitored by the European Chemicals Agency and improvements have been made over the years. In 2015, ECHA released their REACH 2018 Roadmap as a means of simplifying the process of registration and to improve the quality of the information provided in the registration dossiers. This Roadmap breaks down the process into seven steps:
1. Knowing your portfolio and starting now;
2. Finding co-registrants;
3. Co-operating with co-registrants;
4. Assessing hazards and risks;
5. Preparing the registration dossier in IUCLID;
6. Submitting the registration dossier in REACH-IT; and
7. Keeping the registration up-to-date.
Why should you register? Firstly, you have a legal obligation to register if you import or manufacture substances in quantities greater than 1 tonne per annum. If you do not register your substances, you cannot place them on the market in the EU. In addition, there is a social responsibility involved with the manufacture and use of chemicals. The registration and restriction of chemicals will aim to reduce the occupational, public health and environmental impact of using chemicals within the EU. Your registration can ultimately benefit your company as it ensures transparency and therefore safe use for your customers.
The final countdown is looming. Make sure you are aware of your obligations. For more information contact ECHA for support on this pressing topic.