REACH

REACH PRE-REGISTRATION AFTER DECEMBER 1, 2008

REACH is a European chemicals management structure which began in June, 2007, requiring the registration and safety evaluation of chemicals in European commerce at volumes over 1 metric ton per year. Chemicals representing a risk of harm to human health or the environment will be restricted or authorized (banned except for selected applications where risks are controlled).

The REACH system required companies which manufacture or import chemicals or products made from chemicals to “pre-register” them between June 1 and December 1, 2008, in order to group companies into “Shared Information Exchange Fora (SIEF)” where safety or hazard information on specific chemicals is shared. This is intended to reduce redundancy, pool resources and minimize the use of laboratory animals in toxicology testing.

Failure to pre-register results in two scenarios: immediate barring from the EU market, or temporary discontinuation of commercial activity until a “registration” can be submitted. Three weeks after submission of the registration dossier, commercial activity can resume unless a specifically prohibited by the European Chemical Agency (ECHA). The registration dossier is a comprehensive compilation of data which supports the safe use of the substance for the applications described therein. There is a staggered schedule of registration deadlines, with the highest volume substances due first (2010), and lower volumes due in 2013 or 2018.

If a company introduces a new chemical to the EU market, opens an EU market with an existing chemical or crosses the volume threshold of 1 metric ton per year per legal entity, late pre-registration is accepted up until 1 year prior to the registration deadline.

Some companies may not have pre-registered their chemical substances for REACH. Beyond the two scenarios described above, there may be situations allowing late pre-registration. These include:

•  Review of REACH exemptions of selected substances or articles

•  Consideration of who has been the importer-of-record, and who will be the importer-of-record in the future

•  Examination of volumes of imported substance into various countries (various legal entities)

Tox Focus, LLC, is available to assist companies which have not pre-registered for REACH, with exploring strategic options for continued commercial activity in Europe . Please contact Dr. Barbara Vogt at barbara.vogt@toxfocus.com , or 203-355-2819.

Everything You Need To Know About REACH

• TÜV Rheinland REACH
  • 1-TUV-RHEINLAND (1-888-743-4652) for any assistance
  • Brochure 1
  • Brochure 2
• REACH workbook
• REACH Questionnaire for Finished Goods
• REACH Questionnaire for Chemicals
• Your personal REACH Checklist
• Wish to Register Thru TUV BioTech here is what you need to do:
  • Proposal must include the following:
    1. name of substance (IUPAC)
    2. EINECS and CAS number of substance, if available, or any other identity code,
    3. import volume of substance into the Community for the years 2005, 2006 and 2007
    4. intended registering period
    5. Substances which can be applicable for analogy conclusions (for chemical and toxicological properties)

U.S. Department of Commerce has published an updated version of the Trade Finance Guide: A Quick Reference for U.S. Exporters .  This concise and easy-to-understand tool was created specifically to help U.S. small- and medium-sized enterprises (SMEs) navigate the often difficult landscape of trade finance, a topic that is critical for successfully entering and succeeding in today’s increasingly competitive global marketplace.  Last year’s guide generated strong interest from the public:  Over 5,000 hard copies were distributed and the on-line version was downloaded 20,000 times from Commerce websites.

Information on European REACH initiative

• REACH is a major reform of EU chemicals policy, affecting all global supply chains that produce and use chemicals. U.S. exporters to Europe should carefully consider this piece of EU environmental legislation.