# Presentation: 049347

**Are you ready for REACH? **
**Flavie Guerin**
*CS European Union*
*Aquatech, October 2, 2008*

## What is REACH?

- Registration, Evaluation, Authorization and Restriction of CHemicals

- REACH is the new EU chemicals regulation that became law in your countries on 1 June 07
- Implementation started in June 08 (ECHA set up)
- REACH is **not **just for the chemicals industry
- Sectors affected by REACH:
- 	Environmental Technologies		Aerospace
- 	ICT				Textiles
- 	Automotive			Cosmetics
- 	Energy & power generation		Medical & Pharmaceutical

## What chemicals are covered?

- There is no list of chemicals covered by REACH
- All substances **> 1 ton **are covered. There are few exemptions
- REACH applies to chemical _substances_ on their own, in _preparations_ (mixtures) and in _articles_** **(finished products)

## Substances and Preparations

| Substance | Preparation |
| --- | --- |
| 
Titanium dioxide	
 | 
White Paint
[titanium dioxide + ...]	
 |
| 
Ethylene glycol	
 | 
Antifreeze
[ethylene glycol + ...]	
 |
| 
Sodium dodecyl sulphate	
 | 
Washing detergent
(sodium dodecyl sulphate + ...)	
 |
| 
Lavender 	
 | 
Perfume
(Lavender + ...)	
 |

- 	Registration of _substances_: **> 1 ton/year**

- 	Registration
- of _substances in preparations_: applies to every single substance
**> 1 ton/year**

## Articles

- Examples of articles (finished products) under REACH:
- Rules applying to imported articles:
- Products releasing a chemical:  registration of the _substances intended to be released_ from the article
- Products containing  _substances of very high concern_:  simple notification of the substance to the Agency

## REACH FAQ (1)

**FAQ : Are my products covered by REACH?**
**European Chemicals Agency **Website (ECHA):
- REACH 101
- Guidance documents
- REACH Navigator (web-based tool to help determine REACH obligations – free of charge)
**http://echa.europa.eu/**
- Contact  the **U.S. Commercial Service** (EU office):
- Counseling sessions, webinars, trainings
- List of REACH service providers
- Link to REACH websites (National helpdesks)
**http://www.buyusa.gov/europeanunion/reach.html**

## REACH FAQ (2)

**FAQ: How can I find an Only Representative? **
- Non-EU based companies cannot directly (pre)- register . They have 3 options:
- Registration by EU importers
- Establish an EU legal entity
- Or appoint an Only Representative  (OR)
- The EU-based OR will do the (pre)-registration for the non-EU manufacturer
- Concerns about the cost and quality of ORs
- List of ORs on our website: _[http://www.buyusa.gov/europeanunion/reach_bsp.html](http://www.buyusa.gov/europeanunion/reach_bsp.html)_

## REACH FAQ (3)

**FAQ: Is my substance on the Candidate List?**
- Candidate List = list of ‘substances of very high concern’
- The first Candidate List will be published in October 2008 on the ECHA website: _[http://echa.europa.eu/chem_data_en.asp](http://echa.europa.eu/chem_data_en.asp)_;
- 1 substance has already been placed on the Candidate List: triethyl arsenate (carcinogen)
- Watch for more (16 substances identified so far)
- Consequences of Candidate Listing:
- _Authorization_ required for the EU market
- _Notification_ to the Agency of SVHCs in imported products
- _Communication_ to customers and consumers

## REACH deadlines

## Don’t miss the Dec. 1st deadline!

**Pre-registration**

- Deadline : **1 December 08**
- A simple postcard exercise (name of substance and volume)
- No fee
- Not mandatory but key to benefit from extended registration deadlines and secure continued exports

**Registration**

- Deadlines: 2010, 2013, 2018 depending on volume
- Submission of a registration dossier (information on substances properties, uses, safe management). May involve testing.
- Registration fee (up to 1,200 Euros/ substance. SME reduction)

**Pre-registration ends in ... 59 days**

## REACH awareness is low

- A survey by PWC (‘Waking up to REACH’) shows that REACH awareness is low, especially outside Europe and the chemicals industry
- This could lead to a ban on exports to the EU
**Pre-register your chemicals by Dec. 1****st****!**

**Thank you!**