The idea behind the new regulation on chemical substances was to ensure a high degree of protection for health and the environment. REACH places the responsibility for the safety of chemicals with the chemical industry. It is for the industry to ensure that all substances are tested (depending on the quantity in which they are produced or imported) and that safety data regarding their uses is available.
Substances must be registered with the European Chemicals Agency (ECHA, Helsinki) by submitting a registration dossier. All products in the supply chain, from the manufacturer (or importer) to the downstream user, are affected by REACH.
All substances produced in or imported into the European Union are subject to the REACH regulation. Any substance produced or imported in a quantity exceeding 1 metric ton per annum (t pa) must be registered. Existing substances can receive phase-in status; this means immediate registration is not necessary (and can occur during a transition period dependant on tonnage). However, transition periods are available only for those substances that have been pre registered.
Pre-registration requires submission of only a few details such as substance name, CAS and EINECS numbers, name and address of the registrant (legal entity), the tonnage band, and the projected registration deadline. Pre-registration must occur by November 30 2008, at the latest. It is free of charge.
Registration requires the submission of a technical dossier to ECHA, the content of which is determined by the tonnage band that the substance falls into. For existing substances (phase-in substances) in the tonnage band 1 – 10 t pa, physical and chemical data is required (specified in Annex VII of the regulation) as well as available data on toxicology and ecotoxicology.
For substances in quantities > 10 t pa, additional tests are required (specified in Annex VIII). In addition to an extended safety data sheet (eSDS), a chemical safety report (CSR) must also be prepared.
For substances in quantities greater than > 100 t pa, additional requirements regarding possible risks to health and the environment must be fulfilled. Further test proposals must be submitted to ECHA.
The Agency checks the submitted documents for completeness, and decides whether additional tests are necessary (dossier evaluation). In cases of substances giving particular cause for concern, an authorization and restriction process may be required.
As a downstream user, you must inform the manufacturer or importer about all uses of a substance. It might be the case that some of the uses of a substance cannot be supported by the manufacturer. For those uses that are not covered by the manufacturer’s chemical safety report you must prepare your own chemical safety report or stop using the substance.
ROCOL is committed to meeting its obligations under the REACH regulations and has undertaken intensive preparations for implementation. We are aware of the widespread concerns regarding product continuity and are spending a great deal of time talking to customers and suppliers about collaborating with them to clarify product status and to fill in any information gaps that may exist.
You‘ll find a lot of information and more help on the Internet:
Download here.