There are now less than 60 days before the pre-registration deadline for REACH closes.
The REACH regulation - European Regulation (EC 1907/2006) concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) - places greater responsibility on industry to manage the risk of chemical substances they use, and to provide appropriate safety information.
Under REACH, chemical substances (on their own, in ‘preparations’ or in ‘articles’ with an intended release) that are manufactured or imported in quantities above 1 tonne per year per manufacturer/importer will have to be registered. Failure to register a substance prohibits its manufacture, import or use in the EU. Solvents, cleaners, acids, alkalis, oils, lubricants, metalworking fluids are all affected by the scope of REACH.
To assist the process of full registration, a period of pre-registration has been developed. This phase closes on 30 November 2008. Pre-registration is free, and requires manufacturers and importers to provide a ‘postcard’ of information on the substances they have an obligation to register.
Manufacturers and importers who fail to pre-register will not be entitled to take advantage of the transitional periods for registration and will be required to register, in full, 12 months after REACH enters into force. Any manufacturer or importer who does not pre-register cannot expect to rely on support from substance information exchange forums (SIEFs), making registration of a substance potentially both onerous and expensive. Pre-registered information will only be available to those who have pre-registered the same substance (i.e. SIEFs)
For the majority of EEF members, the products that they manufacture would be ‘articles’ (with no intended or foreseeable release) and therefore would not require to be registered under REACH. However, some manufacturers manufacture substances, or import substances on their own or in preparations from non-EU countries, and therefore would have registration obligations.
Another significant factor of REACH is that it places a general ‘duty of care’ on all actors (downstream users) in the supply chain, and introduces a procedure aimed at progressively reducing unacceptable risk caused by substances of very high concern. The impact of REACH to manufacturers is, therefore, considerable.