The US law firm White & Case has published a Q&A document (Q&A) on the EU REACH (Registration, Evaluation, Authorization and Restriction of Chemicals). This measure will be implemented on June 1, 2007.
This document is named "Europe's New Chemicals Legislation Has Worldwide REACH" (Europe's New Chemicals Legislation Has Worldwide REACH). It contains many issues of concern to the electronics-related industries, such as: What types of chemicals are included in the REACH Act? And who must be held responsible for compliance with the Act? This document also discusses the primary obligations, registration requirements and deadlines for pre-registration under the REACH Act.
The summary of REACH Q&A is as follows:
Q1.Does REACH apply to all chemicals?
A1. This method applies to manufacturers and importers who use all chemical substances in the EU. The quantity of raw materials or finished products exceeds one metric ton per year. Regardless of whether these substances are defined as hazardous, they are covered by the REACH Act. .
Q2. Who is responsible for compliance with the REACH Act?
A2. The liability of the REACH Act depends on the role of the company in the supply chain of chemical substances. Broadly speaking, REACH targets manufacturers and importers in the EU; in other words, although the REACH Act does not directly apply to the United States and Manufacturers in Asia, but they still have to provide relevant information about chemical substances to customers who apply their chemicals to products and import them into EU countries; REACH provides third countries with ways to simplify procedures to ensure that non-EU manufacturers can also use EU as the basis for jointly fulfilling responsibilities.
Q3. What obligations will they have to perform?
A3. The person in charge (A2) specified in the REACH Act must register each substance used in the product. In addition, the European Chemicals Agency (ECA) will also start the formal procedures for REACH in June 2008. It is estimated that there are about 30,000 chemicals; any unregistered substances will be completely banned in the EU. Without information, there will be no market.
Q4.What is the deadline for registration?
A4. The existing Inventory of Commercial Chemical Substances (EINECS) is the main target for pre-registration, and is expected to be implemented from June 1, 2008 to the end of 2008; the registration deadline for substances that will be gradually adopted will be based on the substance. The quantity and harmfulness level are December 1, 2010, June 1, 2013, and June 1, 2018 respectively; for substances that are not gradually adopted, registration will begin on June 1, 2008. Q5. Does registration mean the task is completed?
A5. Registration is just the beginning. The EU Chemicals Agency will next conduct dossier evaluation, re-examine the chemical substance information available in the registration file and perform quality evaluation to verify whether the content of the registration file indeed meets regulatory requirements; testing Testing proposals before implementation is also one of the goals of the review.
REACH Q&A file download
- This translation is for reference only. If you have any questions, please refer to the original text of the website. -
Source: "Green SupplyLine website"
