The U.S. law firm White & Case has published a Q&A document regarding the EU's REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation, which will take effect on June 1, 2007.
This document, titled "Europe’s New Chemicals Legislation Has Worldwide REACH," covers many issues of concern to the electronics-related industries, such as: What types of chemicals are included in the REACH Act? And who is responsible for compliance with the Act? The document also explores the primary obligations, registration requirements, and deadlines for pre-registration under the REACH Act.
The REACH Q&A summary is as follows:
Q1. Does the REACH Act apply to all chemicals?
A1. This regulation applies to manufacturers and importers of all chemical substances used within the EU whose raw materials or finished products exceed one metric ton per year, regardless of whether these substances are defined as hazardous.
Q2. Who is responsible for compliance with the REACH Act?
A2. The responsibility for compliance with the REACH Act depends on the role of companies in the chemical substances supply chain. Broadly speaking, REACH applies to manufacturers and importers within the EU. In other words, although the REACH Act does not directly apply to manufacturers in the US and Asia, they are still required to provide relevant information about chemical substances to customers who use their chemicals in products imported into EU countries. REACH provides a simplified procedure for third countries to ensure that non-EU manufacturers can also fulfill their responsibilities on an EU-based basis.
Q3. What obligations will they be required to fulfill?
A3. All persons responsible for REACH (A2) must register each substance used in a product. Furthermore, the European Chemicals Agency (ECA) will begin formal REACH procedures in June 2008, involving an estimated 30,000 chemicals; any unregistered substance will be completely banned in the EU, and without data, there is no market.
Q4. What is the registration deadline?
A4. The existing stock of commercial chemicals (EINECS) is the primary target for pre-registration, expected to be implemented from June 1, 2008 to the end of 2008. The registration deadlines for substances adopted subsequently will be December 1, 2010, June 1, 2013, and June 1, 2018, depending on the quantity and hazard level of the substance. For substances not adopted gradually, registration began on June 1, 2008. Q5. Does registration mean the task is complete?
A5. Registration is only the beginning. The EU Chemicals Agency will then conduct a dossier evaluation, reviewing the available chemical information in the registration file and performing quality assessments to verify whether the content of the registration file truly complies with regulatory requirements. Testing proposals before testing are also part of the review.
Download REACH Q&A document
- This translation is for reference only. Please refer to the original text on the website in case of any issues.
Source: Green SupplyLine website
