REACH in brief
On June 1st, 2007 the regulation (EC) No 1907/2006 concerning the "Registration, Evaluation, Authorisation and restriction of CHemicals" came into force.
The main intention of the REACH regulation is to carry out the Precautionary Principle:
Manufacturers, importers and downstream users shall ensure that the substances they produce, place on the market and use do not adversely affect human health or the environment.
To ensure a high level of protection of human health and the environment the industry is responsible for the estimation and limitation of possible risks while producing and using of chemicals.
The participants in the supply chain do have to fulfill different requirements.
- Manufacturers and Importers of chemicals established in the EU have to analyse and register their substances including all identified uses at the European CHemicals Agency (ECHA).
- Manufacturers and Importers of articles are obligated to inform their customers when their articles contain substances of very high concern (SVHC). These are carcinogenic, mutagenic, reproduction toxic, bioaccumulative and persistent substances as well as substances of similar concern. Furthermore they have to notify the agency when an article contains more than 0.1 % (w./w.) of an SVHC and the amount exceeds an annual quantity of 1 tonne. If the articles contain any substances that are intended to be released the manufacturers and importers shall submit a registration dossier to the ECHA for these substances when exceeding the annual amount of 1 tonne.
- In general there are no registration duties defined for Downstream Users in the REACH legislation. But the exchange of information between downstream users and their customers and suppliers is indispensable. In case of protection of confidential business information (secret uses) it can be necessary to register secret uses of substances by a downstream user himself. Furthermore they have to comply with the information of the safety data sheet.
- Non-EU Manufacturers do not have any legal obligations according to the REACH-regulation. To ensure access to the EU-market the support of EU-registrants is essential. They either have to supply EU-companies with the relevant information to fulfil their registration obligations or they can assign an Only Representative (OR) to keep their business information confidential, to keep their independence and to transfer their responsibility for the registration to a neutral partner.
- Distributors who trade goods within the EU (no import and no use of substances) do not have any registration duties according to the REACH-regulation but communication tasks.
- Non-EU distributors are neither obliged to register any substance nor to assign an Only Representative.
Each company can take different positions in the supply chain and so
has to fulfil distinct tasks and duties.
With our services we support you to find your position in the supply chain.