Despite the REACH Regulation coming into force on 1st June 2007, CMCA(UK) has found that much of industry outside of the chemicals business is not fully aware of what it represents and what its implications are. Recent client forums and engaging with the Chamber of Commerce have led us to believe that the legislation could be a ‘ticking time bomb’ for industry as manufacturers and support agencies are yet to understand what REACH will mean to them. Importantly, it does not just affect the chemicals industry. CMCA(UK) is currently developing a REACH monitoring service as part of our expanding portfolio of tools that are designed to help in identifying and mitigating the effects of obsolescence, especially obsolescence that may be driven by REACH legislation.
The purpose of REACH is in its name:
Registration, Evaluation, Authorisation and Restriction of CHemicals.
Whilst we believe that it is the Authorisation and Restriction elements that will become key to CMCA(UK) and our customers, it is important to understand the purpose of Registration and Evaluation. As a Regulation rather than a Directive, REACH applies directly across all EU Member States as well as Norway, Iceland and Liechtenstein. It is incumbent upon all manufacturers and importers of substances and mixtures within the EEA of >1 tonne per annum to register these with the European Chemicals Agency (ECHA) for evaluation. Where manufacturers or importers are registering the same substance, they are expected to take part in a Substance Information Exchange Forum to be a platform for joint registration. ECHA then evaluate the dossiers and decide whether the substance should go onto their Candidate List for Authorisation.