REACH requires the registration of all chemical substances that are imported,
produced or used in the EU, unless they are exempted. It is estimated that in
the EU more than 30,000 substances will require
registration under REACH. In order to provide for this large registration
load, a phased approach is anticipated. Registration priority is given to
high-volume substances and to substances of special concern, for example those
that may cause cancer.
The graph below shows the timescale of the various phases.
Any exemptions?
Substances that are exempted do not need to be registered under REACH. These
include waste, substances applied in food and feed, active ingredients for
pharma applications and polymers. The monomers of
polymers do, however, need to be registered.
Products that are supplied for research or process research will be subject to
a more relaxed system to permit a 5-year research period using volumes of up
to 1 ton/annum.
Are you an importer or a manufacturer in the EU?
When you import or
manufacture chemical substances in the EU, your substances need to be
registered in accordance with the given schedule.
A subset of the most hazardous substances will require an additional
authorization procedure. This may require the submission of a
Socio-Economic Impact analysis and documentation stating that potential
substitutes have been considered. Use of the substance may be restricted to
specified uses.
Are you a downstream user in the EU?
If you are a downstream user of chemical
substances in the EU you need to verify whether your use conforms to those
listed on the extended safety data sheet for the specific substance. If this
is the case you must apply the appropriate Risk Management Measures (RMMs) to
ensure safe use. If the intended use is not listed you must inform the
supplier and supply the information that is needed for making the risk
assessment for safe use. Alternatively you may register the specific use of
the substance yourself.