Click here for a copy of our REACH - Guidance Notes for Product Exporters to the EU |
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What Is REACH? REACH Stands for Registration, Evaluation and Authorisation of CHemicals. It is a complete re-eveluation of all existing chemicals in use in the EU, and puts in place criteria for introducing new ones. It came into force in June 2007. When the last survey was performed in 1981, there were 100,106 chemicals in use in the EU. Since then another 3800 have been introduced with limited testing. Over 900 chemicals available to the public are known to be carcengenic, mutagenic or toxic to reproduction. There has been very little control over the use of chemicals with onus being on the government to provide testing. However, since 1993, only 141 high-volume chemicals have been identified for risk assessment and possible recommendations for risk reduction, of which only a limited number (28) have completed the process. ref REACH in Brief This lack of information on chemicals that are in use, in applications from the construction industry through to textiles and toys has significant public health and safety ramifications. The European Commission have produced a short video on youtube that details some of the more human drivers behind REACH. REACH will affect any manufacturer that makes products (articles) for the EU market, whether those products are made in the EU or are imported into the EU. It requires that manufacturers know the chemical composition of their products and if certain substances are imported in quantities above certain threshold weights then they have to be registered, and in certain cases registered for that particular use. Hazardous substances, called Substances of Very High Concern (SVHC) may need to be authorised, again potentially for specific defined uses. The onus is on industry to prove the safe use of these chemicals on an application by application basis, along with detailed information on their safe use. All this information will be kept in a database (REACH -IT) and administered by ECHA (European Chemicals Agency) which has been established specifically for REACH. Companies are required to submit registration information using a free tool (UCLID 5) that is available from the ECHA website For companies exporting to the EU, the importer is the legally responsible party with the option of an "only representative" being appointed. . Threshold quantities are per importer, not per manufacturer, so if an importer imports products from several different companies, then he/she will need to know the chemical make up of every product. The 3 main implications for exporters to the EU are 1) Knowing the chemical composition of their products, 2) Substance restrictions of SVHCs, 3) Communication of information on SVHCs with their products. To make this into an even bigger challenge for industry the legislation is hugely complex. The Directive is 849 pages and there are 3000 pages of official guidance. RoHS-International have leveraged their experience on RoHS and plain english interpretation of legislation to produce a Simplified Guide for exporters to the EU. These took 3 months of research, reading, assessing and analysing the REACH Legislation and associated Guidance documents to produce a 29 page detailed guide for all the companies who export Articles (Products) to the EU. Whilst there are many consultancies within the EU supporting companies in REACH there are very few consultants outside of the EU to assist the thousands of companies that export product to the EU. RoHS-International fills this gap and provides the suite of services that companies outside the EU will need to comply with REACH. As well as providing assistance with registration and notification we have a partner company in the EU who will provide the "Only Representative" function for our clients. We will also provide a suite of Simplified Guidance Notes for REACH, starting with our "Simplified REACH Guidance for Product Exporters" Released January 2008. |