European REACH Regulation.

REACH stands for Registration, Evaluation, Authorization and Restriction of Chemicals.

The main objective of REACH Regulation 1907/2006 is to better protect human health and the environment from the risks that all chemicals can pose. At the same time, the aim of the European regulation is to improve the competitiveness of the chemical industry in Europe.

What is REACH?

The premise of the REACH regulation is that manufacturers, importers, distributors and downstream users shall ensure that they manufacture, place on the market or use substances that are not harmful to human health or the environment. To achieve this, the REACH regulation establishes procedures for collecting and assessing information on the properties and hazards of substances placed on the European market.

The scope of the REACH regulation is very broad. The provisions apply not only to substances in their pure form, substances in mixtures or articles, but parts of the regulation also apply to consumer products.

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What can we help our clients with?

Help with role definition in the supply chain.
Maintain REACH substance records.
Submit ECHA registration dossier.
Determine if your product contains Substances of Very High Concern (ZZS).
Check what restrictions apply to your product.

Classification REACH.

Any company that produces, imports or uses chemical substances, mixtures or articles will have to deal with the provisions of the REACH regulation. These can be divided into three categories:

1. Registration of substances.

Certain chemicals are subject to harmonized classification so that risks are adequately controlled throughout the European Union.

2. Authorization of substances, Annex XIV.

The authorization procedure in the REACH regulation aims to control and reduce the use of so-called Substances of Very High Concern (SVHC). If a substance is identified as a SVHC, it is placed on a list of 'substances eligible for authorization' also known as the candidate list.

Inclusion in this list leads to the obligations for suppliers. They must inform ECHA when an article contains more than 0.1% of a ZZS and the total imported or produced volume of the substance exceeds one ton per year. They must also answer consumer questions about the ZZS within 45 days. Finally, they must notify their customers:

Provide a safety data sheet for the substance,
provided with information on safe use.

Thus, substances on the candidate list may still be used under conditions. This changes when the substance is placed on the authorization list.

ECHA decides which substances from the candidate list will be included on the authorization list. This is done on the basis of a substance's properties, widespread use or high volumes. The marketing and use of a substance on the authorization list is prohibited unless an authorization has been granted by ECHA for a particular use.

3. Restrictions on the use of substances, Annex XVII.

This annex contains restrictions on the use of specific substances. These are designed to protect human health and the environment from the risks posed by chemicals.

Annex XVII consists of sections for each substance. Each section contains the description of the restrictions on that substance. These apply only to the specified uses, materials or products.

Our approach.

If you import or sell products under your own brand, you will have to deal with various obligations under REACH.

Our consultants will help you map out these obligations and go through the following steps with you for complete REACH advice.

1. Together we define your role in the supply chain.

We determine whether you:

substances, mixtures or articles imported from outside Europe;
produces substances, mixtures or articles in Europe;
sells substances, mixtures or articles manufactured within Europe under its own brand name.

2. REACH substance record keeping.

Keeping track of imported or manufactured volumes by chemical substance or mixture is essential to understanding your obligations. You can do this by keeping REACH substance records. Without proper records, it is not possible to determine whether or not you need to register a substance.

3. Submit registration dossier to ECHA.

If you import or produce more than 1 ton of a substance, it may not be imported and traded until your registration dossier is approved by ECHA. A registration is not required for excepted substances and for substances you can prove have already been registered by your supplier.

4. Check if your product contains Substances of Very High Concern (ZZS).

You are obliged to check whether the product you want to sell contains ZZS and in what concentration these substances are present. If your product contains ZZS, we will ensure that your substance meets the aforementioned obligations.

5. Check what restrictions apply to your product.

Annex XVII of the REACH regulation. Defines the restrictions on the use of substances. If there are restrictions, you must be able to submit evidence to the market supervisor. We use this to show that your product complies with these restrictions.