Saturday, September 17, 2011

REACH Registration Beginners' Guide

REACH requires all companies manufacturing or placing a substance on the EU market in quantities greater than 1t/year to register that substance with the European Chemicals Agency (ECHA). For legal reasons, only companies with a legal entity in Europe are allowed to submit a registration; however, non-EU companies may submit registration by appointing an EU-based Only Representative to register on their behalf, in which case their importers will be regarded as downstream users and do not need to do registrations.

The Scope of REACH Registration

- Substances manufactured/imported above 1t/y on its own or in preparations;(Note: some substances are exempted.)
- Substances in articles if present above 1 t/y and intended for release(for example, ink a pen);
- Monomer substances if present at a concentration above 2% in a polymer(for polymers, monomers shall be registered);
- Intermediates - reduced requirements and lower costs;
- Substances subject to Product and Process Oriented Research and Development( PPORD ) exempted from registration for 5 (+ 5) years; However, PPORD notification needs to be submitted.

The Deadline of REACH Registration

Substances can be categorized into two groups under REACH: phase-in substances and non phase-in substances. Each group has different REACH registration deadline.

Phase-in substances("existing substances") enjoy benefits of extended registration deadlines if pre-registered before Dec 2008. The principle is that the higher the tonnage, the earlier the registration deadline. Substances classified as CMR1/2 or R50/53(100t/y+)need to be registered before 30 Nov 2010 (see next diagram).

Non phase-in substances("new substances not covered by the definition of a phase in substance") need to be registered immediately before being placed in the EU market.

More info about REACH registration can be found below:
REACH Registration

Reminder: Since Switzerland is not a member of the EU or the European Economic Area (EEA), EU REACH regulation does not apply. Switzerland has its own chemical regulations adopting REACH-like registration and restriction requirements. Please refer to Swiss Chemicals Ordinance (ChemO) and Swiss Chemical Risk Reduction Ordinance (ORRChem) for more info.

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