implement the risk management strategies needed to protect
people and the environment.
Here is some fundamental information about REACH:
REGISTRATION
REACH requires registration of chemical substances made
or imported into the EU in quantities greater than 1 metric
ton per year. This amount applies "per substance" and
"per manufacturer" (or importer). The requirement is for
chemical substances as such and in preparations, and, under
certain conditions, for finished products incorporating those
substances.
REACH assigns the obligation to register to the EU-based
manufacturer or importer. Non-EU-based companies may
appoint an "only representative" (commonly referred to as an
OR) to manage their registration dossiers. The registrations are
submitted to the European Chemicals Agency (ECHA) through
IUCLID soƞware at iuclid.eu.
Registration is mandatory when a company enters a market,
and the deadline for existing chemicals is May 31, 2018. Because
the cost and burden of registering can be daunting, the EU has
exempted some substances. Exemptions relative to the finishing
industry include chemical substances imported into the EU or
manufactured in quantities of less than 1 metric ton, chemical
substances used for R&D;, waste substances, and polymers.
EVALUATION
There are two aspects to REACH evaluation: dossier evaluation
and substance evaluation. The ECHA is required to perform
a compliance check on at least 5 percent of the dossiers
submitted for registration, focusing on completeness and
quality of information. The ECHA notifies registrants of any
deficiencies.
To meet the requirement for substance evaluation, each
year the ECHA and the EU member states select chemical
substances for placement on the Community Rolling Action
Plan, commonly referred to as CoRAP, for further evaluation.
The member states focus on those substances that are
manufactured/imported in large quantities, and that are
persistent and prone to bioaccumulation. Each member state
designates an agency that performs the evaluation.
AUTHORIZATION
U.S. companies that want to export or use within the EU a
chemical substance identified as a "substance of very high
concern" (SVHC) must obtain a "use authorization" to ensure
that such a chemical is adequately controlled and replaced.
Those concerned about whether one of their products requires
an authorization should review the authorization and candidate
lists. (The candidate list includes chemical substances for which
the EU is considering requiring use authorizations.)
Companies that import finished products containing
substances on the candidate list also have certain legal
obligations. The ECHA offers guidance documents on its
website, including articles that specify when a company is
obligated to notify the agency and communicate safe-use
information.
RESTRICTION
Any chemical substance on its own, in a preparation or in
a product may be subject to use restrictions, allowing the
European Commission to control those that are dangerous.
Chemical substances currently subject to restriction can
be found in the REACH Annex XVII, short.pfonline.com/
restrict. Again, the final registration deadline for all phase-in
substances manufactured or imported in the EU in quantities
of at least one metric ton is May 31, 2018. View the ECHA
website at echa.europa.eu/reach-2018 for more information.
OTHER USEFUL INFORMATION
• Competent Authorities meetings on REACH
implementation (CARACAL) bring together the European
Commission, ECHA, member states and stakeholders,
including non-EU countries. U.S. companies can get
information on CARACAL meetings by contacting the
U.S. mission at office.brusselsec@trade.gov.
• The Commercial Service, the trade arm of the U.S.
Department of Commerce, maintains this list of
businesses providing OR and consulting services to U.S.
companies: Ecomundo (Vancouver, British Columbia,
Canada), the European-American Business Organization
Inc. (New York, New York) and Tox Focus LLC (Little
Rock, Arkansas).
GUIDANCE and LEGISLATION
• ECHA offers a number of documents and a question
and answer section to help companies determine their
REACH obligations. Visit echa.europa.eu.
• U.S. exporters may also submit questions to the ECHA
or member state help desks at no charge at
echa.europa.eu/support/helpdesks.
• Inquiries (labeled "REACH Inquiry") also can be emailed
to office.brusselsec@trade.gov.
Rich DePoto is the manager of business development at
Uyemura USA. Visit uyemura.com.
Photo on facing page: European manufacturers and
importers, including those of plated electronics, are
required to provide information on properties of the
chemicals they use.
PRODUCTS FINISHING — PFonline.com
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CONTACT SYSTEM