An introduction to REACH
It is important to understand how the European REACH legislation on chemicals can affect companies throughout the supply chain.
The European Regulation on the Registration, Evaluation, Authorisation (and restriction) of Chemicals (1907/2006) – commonly referred to by the acronym ‘REACH’ – was originally published in December 2006 and has superseded a number of European directives on management and the use of chemicals. The adoption of the regulation was not limited to the European Union (EU), as it was also taken up by three countries outside the EU (Iceland, Liechtenstein and Norway). This larger organisation is known as the European Economic Area (EEA).
The regulation fundamentally changed the way that chemicals were regulated in the region. Prior to the introduction of REACH, suppliers of chemicals (particularly those placed on the market before the introduction in 1981 of a more rigorous approval procedure), would be subject to decisions taken by the EU to restrict the most harmful chemicals. These decisions were based on scientific assessment of substances, where concerns had been raised by academic studies. The result was a fairly slow rate of restrictions, which did not always satisfy the demands of environmental and consumer pressure groups.
With the launch of REACH, this principle was significantly changed, effectively meaning that chemical manufacturers and importers had to demonstrate to the regulators that the substances they supplied did not pose unacceptable risks to human health or the environment.
It is important for each organisation to identify its role within the REACH process in order to determine what actions it would need to take. There are four major categories, and it is possible for any organisation to be more than one. Some larger organisations may have responsibilities under all four:
- chemical manufacturer or importer: Any company manufacturing chemicals in Europe (which are prepared from raw ingredients – whether mineral or organic), or importing chemicals into Europe, will need to register each chemical it manufactures or imports. For the purposes of REACH, an importer of a chemical has the same obligations as that of a manufacturer.
- supplier of preparations: A ‘preparation’ is a mixture of chemicals. In the case of a preparation, each individual chemical present should be registered separately. Examples of preparations could include waterproofing sprays, cleaners and leather polishes. Any substance that is supplied in quantities of one tonne per annum or greater by a single company will require registration, if present as an individual chemical or as part of a preparation.
- downstream users: Chemicals and preparations can be used to make products. During this process, the workers in factories that use these are referred to as ‘downstream users’. REACH requires detailed information on the exposure of downstream users to be available as part of the registration process. Therefore, chemical suppliers need to understand how their products are being used by their industrial customers, in order for them to supply relevant and accurate information.
- suppliers of articles: This category is for the companies that are producing physical products or materials in the EU, or importing them into the EU. It includes footwear and other consumer goods, as well as tanned leathers, finished textile clothes and components. There is no need to register, but there are two distinct sets of requirements that apply to substances in articles. In REACH, these are covered by Annex XVII (mandatory restrictions) and the Candidate List of Substances of Very High Concern (SVHCs).
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