This affects every chemical substance whether on it’s own, in preparations or in articles intended to be released within the EU market. This legislation impacts not only manufacturers and importers but also gives certain responsibilities to downstream users so all of the supply chain is affected.
For manufacturers and importers of chemical substances the legislation means that dependent on the hazard classification and the manufactured/imported volume of the substance that it would need to be registered with ECHA, The European Chemicals Agency from 2010 onwards.
Two of the registration deadlines have passed and the final deadline, 31st May 2018, may seem like a long time away but it is fast approaching. Laboratory testing houses are warning now to prepare and plan for the final registration deadline due to their workload with other concurrent legislation such as The Biocidal Product Regulation. It is likely that if you leave it until 2017 to prepare for the 2018 deadline that you will struggle to find a laboratory with time to conduct your sameness tests etc.
Downstream Users – Do you need to do anything?
Downstream users will have noticed that the introduction of REACh has meant that the information received in safety data sheets has increased dramatically. This is because REACh registration involves ensuring that the substances are used safely, therefore only safe uses can be included in the registration dossier. The registered uses, or exposure scenarios, are communicated via the SDS, known as an extended SDS (extSDS).
If any of your uses / conditions of use appears not to be covered in the extSDS you have 12 months to make the missing use REACh compliant. According to Article 39-1 you may continue to use the substance during that 12-month period, which starts the date you receive the registration number communicated via the extSDS.
Why is my substance no longer available?
Chemical substances are starting to become banned in the EU with those that qualify classed as a Substance of Very High Concern (SVHC). These substances are subject to further scrutiny before being placed on to the Authorisation list known as Annex XIV or more commonly as the ‘Sunset List’. The Sunset List details the substance subject to authorisation, the date after which it can no longer be used in the EU i.e. the ‘sunset date’ and the final date by which authorisation must be applied for. ECHA may grant authorisation i.e. further use of these ‘banned’ substances but this must be applied for and is likely to create a number of restrictions in the supply chain.
For further details please refer to http://echa.europa.eu/support/authorisation
If you require any further REACH information, in particular the authorisation aspect then please email your enquiry to firstname.lastname@example.org