REACH Compliance
Establish whether REACH applies to your substances, what your role requires of you, and what compliance involves.
REACH is Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals, administered by the European Chemicals Agency. It places the burden of identifying and managing chemical risk on the companies that manufacture substances or place them on the European Union market.
What REACH requires
REACH works on the principle that a substance should not be placed on the European Union market unless the risks it presents have been identified and are being managed. In practice that means registering substances with the European Chemicals Agency where the obligation applies, communicating hazard and safe use information down the supply chain, and observing the restrictions and authorisation requirements that attach to certain substances.
Who it applies to
Obligations depend on your role. Manufacturers and importers established in the European Union carry registration duties for substances they manufacture or import at or above one tonne per year per legal entity. Downstream users carry lighter obligations but are not exempt. Distributors principally carry communication duties. Determining your role correctly is the first step, because the entire obligation set follows from it.
Non European Union companies
A company established outside the European Union cannot register under REACH directly. In practice the registration obligation falls on the European Union importer, unless the non European Union manufacturer appoints an Only Representative established in the European Union to take on the registration duties. Which route makes sense is a commercial decision as much as a regulatory one, and it should be settled before goods move.
Restricted and authorised substances
Some substances are restricted, meaning their use is prohibited or permitted only under stated conditions. Others are subject to authorisation and may not be used or placed on the market without it. Separately, substances of very high concern on the candidate list trigger communication obligations. A product can be entirely registrable and still be blocked by one of these lists, so screening the formulation against them belongs early in the process.
What we do
Determine whether REACH applies to your substances and in what role. Establish tonnage bands and what they imply. Screen the formulation against the restriction, authorisation and candidate lists. Advise on the Only Representative question for non European Union manufacturers. Prepare safety data sheets in the format REACH requires. Set out what registration involves where it applies.
What you receive
A written statement of your position under REACH, the obligations that follow from it, the substances that require particular attention, and a prioritised plan. Where documentation is required we can prepare it.
Frequently asked questions
Does REACH apply to my product?
It depends on the substances involved, the quantities, and your role in the supply chain. REACH applies to substances on their own, in mixtures and in certain articles. The starting question is always what you are placing on the European Union market and in what capacity.
We are not based in the European Union. Can we register?
Not directly. A company established outside the European Union can appoint an Only Representative established in the European Union to carry the registration obligations, or the obligation rests with the European Union importer. Both routes have commercial consequences worth settling early.
What is the difference between REACH and CLP?
REACH governs registration and the management of chemical risk. CLP governs how hazards are classified, labelled and packaged. They are separate regulations with separate obligations, and satisfying one does not satisfy the other.
Do we need a safety data sheet under REACH?
The format and content requirements for safety data sheets used in the European Union are set out in REACH. Whether one is required for a given product depends on its classification and how it is supplied.
Not sure where you stand under REACH?
Tell us the substances, the volumes and your role. We will set out what applies and what closing the gaps involves.