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03

No data, no market. REACH reaches everyone!

REACH is an acronym that stands for Registration, Evaluation, Authorization and Restriction of Chemicals. Bearing this name, Regulation 1907/2006 represents one of the most ambitious legislative projects in the EU. Covering the period from June 2007 to 1 June 2018, its implementation was also the reason for the creation of the European Chemical Agency, or ECHA for short.

REACH

REACH pursues the following objectives:

  • To protect health and the environment against the risks posed by chemical substances
  • To develop alternative methods to test the hazardousness of substances
  • To guarantee the free movement of affected products within the EU.

In order to achieve this, products are classified into one of the following groups:

Chemical Element

Mixture

Mixing, Mixture, Solutions which consists out of more than two or more components.

Article

Object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition)

All substances, which are produced within the EC in an amount >1t/a or imported to the EC have to be registered.

Substances are exempted as sufficient information about these substances exists that they are considered to cause minimum risk (Annex IV). Also exempted are substances from sources of particular matter (e.g. LNG; Annex V), polymers (but monomers have to be registered) and substances which are regulated by other legislations (e.g. food, medicine).

To show the complex path of a part from production to supply to the consumer, every player in the supply chain gets one of the following roles:

  • manufacturer (production within the EC)
  • importer (imports into the EC)
  • downstream user (uses product for production of his products)
  • distributor (also tradesman!; stores and place product on the market)

Secure Handling

Every protagonist has to ensure the flow of information about the secure handling of a product at the joint to the following player. To reach the targets protection of the human health and environment substances of very high concern (SVHC) are identified and listed in the so called candidate list. This schedule is constantly updated. Mentioned substances are not deleted from the candidate list and normally will be transferred to Annex XIV of substances subject to authorization.

Pressure sensitivity

And now it becomes interesting because there exist measures which can cause pressure sensitivity:

  • punishment of offence against the REACH-regulation (large monetary fines or imprisonment, dependent on the offence)
  • substances which are mentioned in the candidate list and used from an user more than 1t/a should be notified to the ECHA
  • or the first time the consumer has the right to be informed about SVHC´s in the article he bought. According to Article 33 (2) the consumer has to be informed within 45 days after request if a SVHC is contained in an article.