REACH & CLP Services

From 1 June, 2018 all substances subject to REACH must be registered before they are placed on the EU market.

Registration is one of the processes under REACH where companies are required to collect and assess information on the properties and hazards of the substances they produce or import in the EU. Companies need to prepare a joint dossier for each substance and submit this information to the European Chemicals Agency by the required deadline as follow:

• 30.10.2010: For substances imported/produced in volumes over 1000t/yr. For CRM substances over 1t/yr.
• 31.05.2013: For substances imported/produced in volumes between 100-1000t/yr.
• 31.05.2018: For volumes imported /produced between 1-100t/yr.

Are you first time REACH registrant and don’t know where to start?  Would you like to out-task the whole REACH registration project or parts thereof?

REACHLaw can assist you with your registration as co-registrant or as Lead Registrant. REACHLaw has vast experience in taking companies through the different phases of the registration process including SIEF and Consortium. We provide resources and expertise for the hazard assessment, exposure assessment and risk characterization when needed. We provide the Customer with a complete Chemical Safety Report and necessary collection of information in the supply chain, handling of third party access rights and financial transactions, completing the technical dossier and submitting it to ECHA.

During the REACH registration process the consortium brings to companies an efficient way of cooperation with other registrants to fulfil the REACH requirements within the respective deadlines.

REACHLaw provides support for emerging Consortia with our legal staff drafting the necessary documentation to get your consortium running. We offer managerial support to Consortia under REACH. We ensure that the companies fulfil on time the REACH obligations, and we also facilitate communication and exchange information within the SIEF and within the members of the consortium. In addition we take care of the financial management agreed within the parties.

We perform the technical services in toxicological testing, assessing and compiling environmental effects and data packages compiling and assessing human health, and exposure data, evaluating hazard classification and labeling, exposure scenarios, risk and characterization and preparing chemical safety reports.

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.

Compared with registration, there are relatively few chemicals subject to the authorisation requirement. However as the requirement applies to the use of chemicals, the obligation is on the users of the chemicals and not on manufacturers or importers. Depending on the chemical, the number of impacted users can vary from as few as 1 to 1000’s.

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.

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 for more information

UK REACH Authorisation services

We also prepare UK REACH applications – see our UK REACH services for more information.

Compliance with the REACH regulation is mandatory for any company with the aim to continue selling chemical substances in the EU. Companies located outside the EU need to have an Only Representative (OR) in Europe in order to be able to register their substances.

Our Only Representative service allows Non-EU companies to take part in the REACH registration process. We act as their OR carrying out all the pre-registration and registration work needed to submit a successful registration dossier to ECHA. In addition, we provide a long-term legal presence, client representation and carry out all the mandatory continuous data collection tasks required.

Producers, importers and suppliers of articles located in EU, as well as the Only Representatives from non-EU suppliers of articles, have obligations under REACH. The latter actors may have the following requirements: i) registration obligations may apply if the article contains substances intended to be released with a volumes of > 1tonne/yr. ii) Notification obligations may apply if the article contains listed Substances of Very High Concern (SVHC) iii) If the article contains SVHC substances this information needs to be notified along the supply chain.

We assist companies with the following services: SVHC notification, SVHC identification, Notification-Exemption study, SVHC inventory and monitoring, article study and corporate level consulting.

After the REACH and CLP legislations entered into force, the Chemical Safety Data Sheet (SDS) has become the vehicle of communication within the entire supply chain in the EU.

The supplier of the substance or preparation must supply and update the SDS in accordance with Annex II of the REACH regulation and taking into consideration the CLP requirements.

In addition, for all the substances where a chemical safety report (CSR) is required, the information in the SDS must be consistent with the CSR and the relevant exposure scenarios (ESs), shall be annexed to the SDS. SDS containing ESs is commonly named as Extended SDS (eSDS).

REACHLaw provides companies REACH & CLP compliant SDSs as well as Extended SDSs. We also provide translated SDS’s and eSDS to the official languages where the product is placed.

Our legal services help companies to anticipate and manage additional regulatory demands emanating from the different REACH processes and other product Environmental, Human and Safety- EHS- related market access restrictions globally. Additionally, we also help companies to clarify whether their substances/preparations are exempted from REACH.

Likewise, our legal experts assist our clients in the management of REACH compliance issues in the supply chain and in REACH due to diligence processes related to mergers, acquisitions and other company transactions.

REACHLaw help you with identifying your CLP regulatory obligations and with compiling the notification dossiers, authoring of labels and re-classification of your substances/mixtures to meet the CLP requirements.

Our Support Includes:

• CLP Labels
• Substance Classification