Are you ready for REACH?

On the 13th December, 2006, REACH (Registration, Evaluation, Authorisation and Restriction of CHemicals) was unanimously adopted by the EU Parliament and is now due to enter into force on the 1st June, 2007.

If you are an EU manufacturer of paper chemicals, an EU representative of a non-EU manufacturer (referred to as an 'only representative'), the clock is ticking and there is much to do to prepare and comply with this extensive legislation from the EU. The timescales are:

• June 2007: REACH regulation comes into force. Time for EU manufaturers and importers to collect available information; locate other relevant information holders; consider consortia; and share information.
  
• June 2008: European Chemicals Agency becomes operational and the pre-registration phase starts. For substances > 10 metric tonnes carry out a chemical safety assessment (CSA) and write the chemical safety report (CSR). Communicate down the supply chain. Registration timescales depend on the tonnage or whether the substance is of very high concern (SVHC).
  
• Dec 2010: Submission of dossiers and CSRs via IUCLID 5 (submission software available in June 2007) for: 1. Substances of very high concern and classed as CMR, PBT and vPvB, and 2. Substances produced or imported in quantities above 1,000 tonnes.
• Dec 2013: Submission of dossiers and CSRs for: Substances produced or imported in quantities between 100 and 1,000 tonnes.
  
• June 2018: Registration phase closes with submission dossiers and CSRs required for substances produced in smaller quantities (>1 metric tonne).

Some paper chemical companies have been getting ready for a while and participated in the development of the REACH legislation. There are associations such as CEFIC who represent a larger body of chemicals manufacturers and provide help and advice to their members. There are also country organisations and a growing number of knowledgeable independent companies willing to give help and advice.

This is a big piece of legislation and there are many unknowns ....... probably best to ride the wave and keep abreast of what is going on ..........

If anyone has any good advice or thoughts, please comment.