REACH, which stands for Registration, Evaluation, and Authorisation of Chemicals, is an EU regulation laying down the obligations for EU enterprises which manufacture, import, distribute or use chemical substances or mixtures.

Registration: Companies which import or manufacture chemical substances in the EU are required to register these harmful substances with the European Chemicals Agency (ECHA)

Evaluation: The registered data is used to assess the extent to which the substances are hazardous. This assessment can lead to the substances being included on the REACH Candidate List and, possibly, at a later stage, included on the REACH Authorisation List:

● The Candidate List: If a substance is assessed to be of very high concern, e.g. carcinogenic, it may be included on the Candidate List in REACH.

● Authorisation List: If a substance is of grave concern to the environment and health, it may, at a later stage, be included on the Authorisation List in REACH.

Authorisation: Enterprises which need to use a substance from the Authorisation List in their production must obtain authorisation from the European Chemicals Agency. Enterprises must adhere to the deadlines for applications for authorisation; otherwise, use of the substance will be prohibited.

Find out more about REACH compliance and get practical and expert assistance.

If you import chemicals to the EU grounds, you will have two choices towards REACH obligations:

1. Do your own registration.

2. Buy products from REACH compliant suppliers.

Let’s explore some tips that will guide and help you properly meet all the REACH obligations implemented on your business.

Tips to help you achieve REACH compliance

Tip 1 – Do your own registration, if necessary

It is easily possible for you to register products by yourself if your supplier chooses not to complete registration. The registration fee imposed by ECHA is tonnage and company-size specific, and as such, SMEs are charged lower fees to engage in the registration process for their substances.

Also, you shouldn’t confuse REACH requirements with the ECHA SCIP database.

Both serve different purposes as individual frameworks. The EU SCIP database has set forth Jan 5th, 2021 as the start to receive submissions from suppliers.

Know the clear differences between ECHA SCIP database and the REACH by clicking here.

Tip 2 – Source only REACH registered chemicals & suppliers

It is highly recommended to only source for chemicals & suppliers who are rightfully registered with REACH. This small step will ensure you don’t end up wasting time with reconciliation and all the steps in the compliance process are met with proper due diligence and authority.

Tip 3 – Get your goods certified

EU importers face penalties for violations. To avoid these potential violations, importers should contact the only representative of their suppliers and get the goods certified (imported goods). Importers also often get confused between the REACH and SCIP submission process, and often commit a majority of their mistakes there in the submission process.

There are many types of questions associated with documenting any type of compliance when the goods are at the point of entry in the Customs territory of the EU. These questions are directly aimed at the pre-registration processes, exemptions of substances from registration, and other parts of the submission process.

Click here to understand the various REACH offences summarised by OECD.

REACH Article 33 obligations are to be strictly adhered to avoid any kind of penalties

Tip 4 – Always request for REACH compliant SDS

Based on a REACH mandate, SDS shall be updated accordingly and meet the requirements of the REACH regulation. REACH also clearly states the type of data that should or could be included in the SDS.

Importers in the EU and elsewhere should always remember to request REACH compliant SDS or prepare their own SDS.

Wrapping Up

The most reliable way to identify those hazardous substances is through laboratory testing. As an individual or an organisation, you can carry out testing by yourselves or ask your suppliers to do it.

In order to completely adjust to the REACH requirements, you can look for a 3rd party vendor to help with all the intricacies and groundwork. APA engineering has the right resources and experience to assist you. Be it the tricky SCIP ECHA database, REACH compliance, conflict materials, IMDS, or any other compliances or regulations, APA Engineering will guide you through all the steps to make your submission process convenient and seamless. Contact our success managers today, and explore our expertise and experience in regulatory management services across industries today.



If this regulation is applicable to you and you are interested in knowing more about this topic and available solutions, then schedule a free consult with our experts.