If REACH Policy Reform is something you have heard about, but as it is all about chemicals has no impact on your company, then it maybe time to think again.
Here I look at a couple of frequently asked questions and try and explain who, and how, could be affected:
Q1: What does REACH mean for your company?
A: You are affected if you:
Manufacture or import chemical substances or mixtures of chemical substances (preparations such as paint, adhesives etc)
Produce or import articles such as electronic components, sub-assemblies, toys etc, which contain substances to be included in a list of “substances of very high concern” (notification required if >0.1% by weight and >1 tonne per annum) or which are intentionally released or release is reasonably foreseeable (eg ink or perfume) during their use, or during recycling (registration required if >1 tonne per annum).
Process chemicals or you formulate preparations for end use (for example cleaning products, paints or motor oils) or you use these formulated products professionally. In this case you are a “downstream user”
Q2: How will you be affected?
A: If you are a:
Manufacturer / Importer – you manufacture or import a substance on its own or in a preparation of more than 1 tonne per year
Producer / Importer or Supplier of articles – you manufacture / import articles or place them on the market
Distributor (including retailers) – you store and place on the market a substance, on its own or in a preparation
Downstream User – you use a substance, either on its own or in a preparation, in the course of industrial or professional activities, (for example: formulation, dilution, repackaging, spraying, painting)
Note: companies outside the EU cannot register chemicals themselves but can appoint an EU based “only representative” to act on their behalf
REACH is the most complicated of all EU regulations impacting our industry and, through this column, I will endeavour to bring clarity on the key points.
Directive Decoder
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