REACH Compliance

You can check the substances on the publicly accessible databases as maintained by the ECHA for all major REACH registered lists. Businesses interested in registration and those who need compliance can check the SVHC candidate list, Annex XIV Authorization, and Annex XVII Restriction list- all through the ECHA website, which are updated regularly by the said regulator.
ECHA also provides an SCIP database for articles that contain SVHCs. Let us help you subscribe and get notifications on time and integrate list monitoring into your compliance workflows.

In simple words, compliance basically means that you meet every criterion for registration, evaluation, authorization, and restrictions of chemicals under the EC No. 1907/2006. The regulation's main objective is safe manufacture, import, and use of chemicals in the European Economic Area.

The registration applies to manufacturers, importers, distributors, and producers/importers of articles that meet the criteria under the EU regulations.

Well, the application is more nuanced in practice, while REACH does not directly apply to companies outside the EU, it will affect them if such legal entities want to export into the EU market. If you do want to export, then you will have to appoint a local "only representative" to obtain approval.

An only representative can be an individual or a legal entity who is either resident or established in the EU/EEA who can be appointed by a non-EU manufacturer or an exporter, article producer, or formulator that wants to sell, export, and manufacture in the EU via REACH registration obligations.

The details that are needed while you apply for the registration are the substance's identity, physicochemical properties, toxicological & ecotoxicological information, uses, exposure of the substance, classification, labelling, safety test reports, and chemical assessment/safety reports (when needed).

Well, generally polymers are exempt from registration, but some substances like monomers and related chemicals may still need to be registered in case they meet the requirements of REACH.

In case a chemical is already registered, then you, as a new applicant, will have to rely on that existing registration data through a data sharing arrangement under the REACH while also fulfilling your share of obligations.

You will get entangled with substantial fines, enforcement actions, restrictions on your products, customs barriers, full goods recall, and any other action as deemed fit by the concerned EU state.

A data sheet provides information on a substance or mixture's hazards, safe handling, transport, emergency measures, and disposal. So, when a company applies for REACH, they need to submit an SDS report under the EU and CLP regulations.

Your timeframe for the complete approval depends on various factors like the complexity of the substance, availability of the data, the number of times testing is needed, joint data arrangement, and dossier preparation. While simple applications can be done in three to six months, most complex cases take longer, such as 12 to 24 months.

Well, not always, but in certain cases it does. Sometimes, producers and importers of articles may have REACH compliance obligations in case their articles do contain substances that indeed get released during normal use or are of substances of very great concern.

A substance of very great concern is a list of chemicals that, as per ECHA, pose a serious hazard, such as carcinogenicity, reproductive toxicity, mutagenicity, persistence, and bioaccumulation. The SVHCs get added in the candidate list, and later they become open for authorizations.

Most businesses get confused thinking that once they get the approval, they are fully compliant with all the rules, but that is where they get it wrong. In practice, once you get the registration, you must keep the registration updated when new information becomes available to you, any regulatory information changes, or the volume changes. Post-registration compliance is most important throughout the supply chain and involves constant monitoring of regulatory development.