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REACH: for manufacturers of chemicals

 
   
This is one of three articles on REACH. We have a general introduction to REACH which you should read first. The other article is written for businesses who use chemicals.
 
 
 
This article will be useful reading for all small business owners and managers.
 
 
 
What is REACH?
 
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the new system for controlling chemicals in Europe. The regulations took effect in the UK from 1 June 2007.
 
 
 
Its aims are to:
 
  • Provide a high level of protection of human health and the environment from the use of chemicals;
  • To make the people who place chemicals on the market responsible for understanding and managing the risks associated with their use;
  • To enhance innovation in and the competitiveness of the EU chemicals industry.
 
 
 
This article provides basic information to help you understand how you as a chemical producer could be affected by REACH.
 
 
 
How might REACH affect your business?
 
Chemical’ means an individual substance, not combinations (mixtures, formulations, preparations) of two or more substances.
 
 
 
If you make chemicals either to use yourself or to supply to other people (even if you export them) it is likely that you will have a duty under the regulations.
 
 
 
Chemicals covered by REACH
 
Any chemical that is manufactured in quantities of 1 tonne per year or more is covered by REACH.
 
 
 
There are a few exceptions including:
 
  • Radioactive substances;
  • Those in transit;
  • Waste (as defined in EU Directives); and
  • Intermediates that only exist during an enclosed reaction.
 
 
 
What is my duty?
 
If you want to continue to manufacture chemicals covered by REACH you will need to register them with the new European Chemicals Agency (ECHA) in Helsinki. Registration means providing a package of technical information on the chemical and its hazards to the ECHA.
 
 
 
Registration is phased over a period of years based on tonnage levels and in some cases the hazards of the chemical. However, to take advantage of the phase in time you will need to pre-register between 1 June and 30 November 2008.
 
 
 
What information do I need to tell ECHA?
 
For each chemical you will need to tell them the following:
 
  • Name of the chemical including an identifying number (for example CAS or EINECS number);
  • Your company’s name and address and a contact name;
  • Envisaged deadline for registration and tonnage band; and
  • Identifier information of any structurally similar chemical which you may wish to rely on to provide useful evidence on hazards as part of your registration package.
 
 
 
Will it affect my business?
 
Another benefit of pre-registering a chemical is that you will become part of a group of companies who have also pre-registered that same chemical. This group, called a Substance Information Exchange Forum (SIEF) will share information on hazards so that only one set of technical information has to be submitted to the ECHA.
 
 
 
The SIEF will work collectively on other aspects of the registration package.
 
 
 
Membership of a SIEF will also help to share expertise and spread costs with members paying reduced registration fees. Our advice - pre-register; as it may save you a lot of time and money later.
 
 
If by chance you find any error in this information page, do please tell us. We should also welcome your suggestions for new subjects for information pages. These notes:
    Do not provide a complete or authoritative statement of the law;
    Do not constitute legal advice by Net Lawman;
    Do not create a contractual relationship;
    Do not form part of any other advice, whether paid or free.

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