How to Get Your Products Ready for REACH

A Guide for Article Manufacturers

By John Fox
Director, Business Development
Synapsis Technology, Inc.

The European Union's new REACH regulation puts your products - and profits - at risk. REACH, which stands for "Registration, Evaluation, Authorization and Restriction of Chemicals," is intended to ensure that all chemicals are tested and used in safe ways. And although REACH certainly affects chemical manufacturers, it also has a profound impact on the makers of all products - even those not sold in Europe. So, whether your company makes computers, automobiles, toys, or textiles - or the components that go into these products - you need to understand REACH and take action now to get your products ready for REACH.

This guide provides a quick summary of what you need to know about REACH, as a product manufacturer, or, as REACH refers to you, an "article manufacturer." You'll learn how REACH imposes brand new market requirements which could essentially ban your products - or your customer's products - from being sold in Europe. You'll also learn how, even if your products are not destined for the European market, they still could be torpedoed by REACH. By altering the way global chemical companies do business, REACH will alter the world's supply chains, potentially increasing your costs or jeopardizing the availability of the parts, materials, and chemicals you buy.

Finally, this guide will present a plan to help you identify and manage these risks, and examine the benefits of incorporating data management systems into your REACH compliance program

What is REACH?

Laws banning toxic substances in products have been around for years, but historically focused on individual substances, products, industries, and uses. The groundbreaking ideas behind REACH originated out of the desire to replace the patchwork of existing regulations in Europe with a more comprehensive law - one that encompasses all chemicals, including those placed on the market before 1981, when the industry did not systematically provide documented health and safety information.

REACH went into effect on June 1, 2007. It takes a precautious stance, meaning the burden is placed on industry to prove that the chemicals it produces, uses, and places on the market in significant quantities are safe for humans and the environment. As a result an estimated 30,000 chemicals are expected to be regulated by REACH. It's also expected that up to 3,000 substances will ultimately be banned, or "restricted," under REACH. These so-called Substances of Very High Concern (SVHCs) will include CMRs (carcinogens, mutagens, and toxic to reproduction) and other substances.

With such an ambitious agenda it's not surprising that the REACH document itself is lengthy. It consists of 1,000 pages of legal text and technical annexes and has been called one of the most complex texts in the history of the EU. There are ten supporting guideline documents, each addressing the requirements of various stakeholders and elements of the law, and together total more than 4,000 pages.

The 4 Elements of REACH

REACH sets up an agency - the European Chemicals Agency (ECHA) - to oversee the four key procedures of the law:

  1. Registration: Registration is an information gathering and risk management exercise. Manufacturers of substances that are imported into the EU in quantities over 1 metric ton per year must register these substances by submitting a dossier which includes data on the chemical's properties, uses, and safe management. The goal is to have one registration per substance so companies may have to register jointly.
  2. Evaluation: The Agency evaluates the registration information to determine the chemical's hazards and risks.
  3. Authorization: Authorization applies to SVHCs and will be company-specific, use-specific, and time-limited. Lists of candidate and official SVHCs will be issued on a rolling basis. The 1 metric ton threshold doesn't apply to authorization.
  4. Restriction: The goal of authorization is to find safe alternatives for the SVHCs and eventually restrict, or ban, these substances for specific uses.

How Will REACH Impact Your Company?

REACH defines an article as "an object which during production is given special shape surface or design which determines its function to a greater degree than its chemical composition. " That's a mouthful but generally refers to products like computers, cars, toys, textiles, and furniture - things that aren't substances or mixtures of substances like paint.

As an article maker, you have four key risk areas to consider...

How to Get Your Products Ready for REACH: A Guide for Article Manufacturers

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You'll learn:

  • 4 ways REACH will impact your products and supply chain
  • 8 key questions you need to answer to comply with REACH
  • 10 steps you can take now to get ready for REACH

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