Our Authorisation Team is ready to assist you in the development of your authorisation strategy, preparation of the application and successful navigation of the assessment process.
The REACH Authorisation List gives the list of chemicals that are subject to the Authorisation requirement. In practice, this means that chemicals covered by an entry on the List may only be used based on a granted authorisation from the European Commission unless otherwise exempted from the authorisation requirement (e.g. intermediate use, SR&D exemption, defence exemption). The list is regularly updated and in principle, any chemical with so called “substance of very high concern (SVHC)” status may be added. There are currently 59 entries on the Authorisation List and 230+ entries on the SVHC list.
If you are a user of a chemical listed (e.g. chromium trioxide) or you use components/products that require use of the chemical in their production (e.g. chrome plated parts), the authorisation requirement will impact your business. Without a granted authorisation, use must cease after a date given in the entry (the so-called sunset date). For example the sunset date for use of chromium trioxide was the 27 September 2017. If you need to continue use of a chemical on the Authorisation List after the sunset date, you will need authorisation. Authorisation is granted by the European Commission via a formal application process.
Your authorisation strategy
Our team will assist you develop your strategy (use mapping, number of uses in scope, uses exempt from authorisation, applying as an individual user or a group of users) and then assist you at every step in the application process.
The authorisation application process
The application consists of 3 main parts
- An analysis of alternatives (AoA) report that describes your efforts to identify suitable alternatives and either an R&D plan or substitution plan to phase out your current use
- A chemical safety report (CSR) that includes your exposure assessment and risk characterisation that demonstrates the chemical is used safely
- A socio-economic analysis (SEA) that demonstrates that the benefits from continued use outweigh the monestised risks
After submission to ECHA, the ECHA committees will assess the reports and give their recommendation on granting/refusing authorisation in an opinion issued to the European Commission. The committees may ask for additional information during their assessment. The European Commission will take a decision based on the opinion and their own assessment.
Contact our team
We have prepared more than 30 applications covering upstream and downstream, individual and joint. We have the expertise in-house and will assist you with every step towards a successful application
Is your use covered by an exemption or do you need to apply for an exemption (e.g. defence)?
We also prepare Defence exemptions following the European Defence Agency (EDA) code of conduct – contact us for more information
Do you consider your use is exempt? We can assist you documenting your decision – contact us at email@example.com for more information.