REACH is an acronym for Registration, Evaluation, Authorization and restriction of Chemicals. REACH is a regulation of the European Union, adopted to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry. It also promotes alternative methods for the hazard assessment of substances in order to reduce the number of tests on animals.
The requirements of REACH apply to all chemical substances, including those used in industrial processes, as well as consumer products. This means REACH applies to all solvents, paints, fuels, electronic devices, electrical equipment and appliances, and even clothing.
REACH requires all organizations that manufacture, or import chemical substances into the EU to register those substances. Registration can be done online through the IUCLID website.
The ECHA evaluates each registration for compliance with REACH. As a part of the evaluation, an ECHA scientific committee may study the substance to evaluate the risks it presents, and whether those risks can be managed. The ECHA may decide that the use of the substance must be restricted, or that prior authorization is required to use the substance. In addition, countries within the EU may also evaluate the substances to determine if they have any concerns.
There are some chemical substances that are exempt from the REACH registration requirements. These include chemical substances:
Other substances, listed in Annexes IV and V of the REACH regulation, are exempt if they have not been modified. These include:
The REACH requirements for registration are being phased in, over an eight year period. The deadlines are based on the quantity manufactured or imported. The dates are:
In addition, some highly toxic chemicals were required to be registered by December 1, 2010, without regard to quantity. Substances that are released to the environment under normal conditions must also be registered.
Manufacturing paint provides a simple example. The paint manufacturer purchases pigments and other ingredient chemicals, which must be registered with the ECHA. The suppliers of those chemicals are responsible for the registration, and for providing a Safety Data Sheet (SDS) with accurate and complete information to the paint manufacturer. The paint manufacturer must then supply their customers with a SDS for the paint.
Customers also have responsibilities under REACH. They must:
Companies outside the EU have no direct responsibilities under REACH. It is the responsibility of the importer, who brings the substance into the EU, to pre-register or register the substance. However, non-EU companies exporting to the EU should be aware of the REACH requirements.
Substances that have been designated by the EU as a "substance of very high concern" (SVHC) must have use-authorization before being imported. As a business practice, then, non-EU companies must ensure that use-authorization has been obtained before shipping the substance to the EU. Otherwise, the shipment may be returned. SVHCs are defined by the ECHA as those substances:
SVHCs may be authorized for use in the EU, but, depending on the substance, they may not be sold or used after a specified date without either an authorization or an exemption for a specific use.
Non-EU companies that wish to determine whether a product requires an authorization can check the "authorization list" (REACH Annex XIV). There is also a "candidate list" identifying those substances currently being considered for use-authorization requirements.
Understanding and complying with REACH can be complex. To help companies comply with the requirements of REACH, there is a helpful online resource. The Navigator is a tool that can assist in clarifying your role under REACH, identify your obligations, and help you find relevant guidance documents, manuals, legislation, and other information. However, keep in mind that the Navigator is just an online tool. It can only provide generic information. It does not solve specific problems, such as classifying a particular substance. Need an overview of OSHA's chemical labeling rules, elements of a HazCom 2012 label, and how to meet requirements? Download our free guide below.