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EU legislation: What exporters need to know about REACH

REACH is the chemical legislation of the EU that came into force on 1st June 2007 through Regulation (EC) No. 1907/2006. REACH will establish a new single regime throughout the 27 EU Member States for existing and new substances and requires manufacturers in the EU and EU importers of substances/preparations to register them. The Regulation itself counts almost 900 pages besides the many other documents, guidance papers and opinions that can be found on Internet.

In general one can say that companies outside the EU (1) manufacturing substances or preparations or (2) using substances or preparations that still can be found in the finished product, are not directly accountable, however:

  • EU importers might request additional information from their suppliers in order to do their own registration for REACH.
  • Be aware that in some cases you will have to refer to your own suppliers to get all data together.
  • When costs are involved for EU parties, for example to create a dossier, part of the costs might be passed through to the supplier.
  • In a few cases EU importers might request from their suppliers to do the registration themselves, then they are directly involved.

What is REACH?
REACH is the Regulation in the EU on chemicals and their safe use. It deals with the Registration, Evaluation, Authorisation and Restriction of Chemical substances. The new
Regulation entered into force on 1st June 2007 and will be implemented in phases within the next 10 years. Presently, REACH requirements for registration entered into effect.

The REACH legislation is an EU Regulation which means that it is implemented in all 27 Member States in the same way. REACH is therefore fully harmonised. In addition, Iceland, Lichtenstein and Norway, which are part of the European Economic Area, are planning to transpose REACH to their national legislation. When this has taken place the same requirements apply to exports to these countries.

Which products are included?
The following products are included in REACH:

  • substances, such as base chemicals, speciality chemicals, metals, additives, solvents, monomers and natural substances if they are chemically modified
  • mixtures or preparations of chemical substances, for instance cleaning products, formulated process chemicals, paints and motor oils
  • articles which contain substances which are intentionally released during their use, for example the fragrance in a scented candle
  • articles which contain dangerous substances which are not intentionally released during their use, such as phthalates in garments
  • substances in products/containers, such as ink in cartridges
  • substances which are on a candidate list of “substances of very high concern”
  • new substances

What happens if the chemical is not pre-registered?
The pre-registration is very important, because from 1st December 2008 onwards the manufacture in the EU and import of chemicals will only be allowed if the chemical is proper pre-registered. Substances that are not pre-registered need to be registered as a new substance which is a more complicated process.

For more information on the Candidate List of Substances of Very High Concern and other details about the legislation, refer to the REACH website.