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.

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.

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.

Authorisation and restriction are regulatory tools designed to manage risks and safeguard human health and the environment from chemicals with hazardous properties. 

A Substance of Very High Concern (SVHC) is a chemical identified as posing major risks to health or the environment. Chemicals with SVHC status are placed on the “Candidate List” because they may eventually require authorisation. If added to the Authorisation List, the use of these chemicals is prohibited unless authorized or exempt. Authorisation for specific uses requires a formal application process, with the European Commission making the final decision. 

We provide a full range of  authorisation services for both EU and UK REACH. For details, visit our authorisation services page. (Click here ) 

EU member states or the European Chemicals Agency (ECHA) can propose restrictions if they find that certain chemical risks are not adequately controlled and should be managed across the EU. Restrictions can limit or ban the manufacturing, marketing, or use of a substance. These restrictions may apply to any substance on its own, in mixtures, or in products, including those that don’t require registration. ECHA can also propose restrictions on products that contain substances listed for authorization.  

Restriction proposals are open for public consultation to gather feedback from stakeholders, including industry, NGOs, public authorities, and the public. The proposals are evaluated by ECHA’s scientific committees, who assess the justification for the restriction, socio-economic impact, availability of alternatives, proportionality, and enforceability. The ECHA committees’ opinion is sent to the European Commission for a final decision. Once adopted, the restriction becomes legally binding. 

We offer a range of support services for stakeholders wishing to contribute to this process. For more information, visit our restriction support services page. (Click here)

Due to our extensive experience in regulatory compliance, especially in REACH, we are uniquely positioned to support organizations in evaluating the potential consequences of a proposed action, policy and regulation arising from EU legislation. Our experts have prepared more than 50 impact assessments, namely Socio-economic Analyses (SEA), supporting our clients’ REACH Authorisation or Restriction needs. In our impact assessments, we aim to quantify and monetise the impacts (economic, social and environmental) as far as practically possible to enable a precise and robust comparison of the positive and negative impacts.

Visit the following (LINK) and learn more about REACHLaw Impact Assessment Services.

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.

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

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.