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The registration, evaluation, authorisation and restriction
of chemicals (REACH) programme began its pre-registration
period on 1 June - meaning that companies will need to research
the substances they use, how they use them and who they rely
on if they want to keep using them in the future.
Under REACH, chemicals manufactured or imported into the
EU in quantities of more than one tonne must be registered
with the European Chemicals Agency (ECHA)
in Helsinki. This process began with the pre-registration
period, which runs until 1 December this year.
However, REACH will not only affect big businesses dealing
with large quantities of chemical products. If companies use
chemicals to keep their machinery operating and their premises
clean, import products such as cars or batteries or receive
substances containing chemicals through a supplier and use
them in an unusual manner, they may need to take some action
under the new rules.
Who will be affected by the rules?
1) Companies that make their own chemicals or supply
them to others - if they manufacture one tonne or more of
any chemical in a year.
2) Businesses importing one tonne or more of chemicals
into Europe per year - including those in mixtures such as
paints and cleaning agents and products such as cars and batteries.
3) Those using substances to keep their machinery
operating and premises clean; formulators of paints, glues,
detergents, plastics or rubbers; users of oils, lubricants
and antifoams; car repair shops and cleaners and manufacturers
of electronic components, computers and toys.
Companies that manufacture or import more than a tonne of
chemicals or more a year, will need to be aware of the make-up
of these products in order to pre-register. This includes
substances used and all the ingredients of any mixtures. If
a company produces finished products such as cars, batteries
or 'phones, it will need to find out if there are substances
in these products that exceed one tonne per year.
If a business purchases substances from a supplier, it will
need to look at what they are and how it uses them. If a company
uses a chemical in an unusual way, it might need to let its
supplier know, as it will need the information for registration.
Generally, if a business is using chemicals or mixtures of
chemicals - such as paint, lubricants or cleaning agents -
in the way that is expected, REACH will probably not mean
significant changes. However, if it uses unusual chemicals,
the company should contact its supplier to check how it plans
to supply the chemical in the future.
Pre-registration involves providing the ECHA with some basic
information on the substances that a business is manufacturing
or importing, the quantities involved and the details of that
firm's REACH contact.
To pre-register, a company will need to meet certain criteria.
Generally, chemicals need to be on the 'existing substances'
list of the European inventory of existing chemical substances
(EINECS),
which means it must also have been placed on the European
market before 1981. Specific guidance on this can be found
on the REACH website.
If a company takes part in the pre-registration process,
it will be able to take a longer time to fully register. The
timing of these deadlines depends on the hazard classification
and tonnage of the substance being registered.
If a company does not pre-register, it cannot take advantage
of these staggered deadlines and will need to fully register
its substance(s) immediately after 1 December - ceasing its
manufacture or import while this takes place.
Once pre-registration has taken place, the ECHA will identify
those that have pre-registered the same substance and will
put them in contact with each other. The potential registrants
can then get together and form a 'Substance Information
Exchange Forum' (SIEF)
where they can negotiate sharing their available data and
the costs of generating any new information for a joint substance
registration dossier. Registration costs are also reduced
through this collaboration.
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