REACH – Important points
REACH is a European Community Regulation on chemicals and their safe use. It deals with the Registration, Evaluation, Authorisation and Restriction of Chemical substances. The new law entered into force on 1 June 2007. Download a brief on this regulation. Detailed information may be obtained from http://echa.europa.eu/home_en.asp.
A points to be noted are given below:
- Polymers are not covered under the REACH ambit. The EC regulation clearly defines polymers. However, monomers in a polymer fall under REACH and must be registered.
- Among the items that fall under our Council, masterbatches and the ink used in writing instruments fall under ambit of REACH and therefore exporters/manufacturers must take necessary action.
- With regard to other plastic processed goods (which possibly fall under the “articles” as defined in the REACH regulation) – these are generally not covered and a communication received from ECHA (the European Agency monitoring REACH) against our query may be viewed here.
- It is advisable that all chemicals falling under REACH (monomers, chemicals in masterbatches, inks in writing instruments and other chemicals in polymers) be pre-registered before December 1, 2008. Pre-registration is a one-time facility offered by the European Commission till 1st December 2008 which will give a cushion to the registration.
- Registration is a more cumbersome process. The deadlines for registration if pre-registered will be 2010 for imports of the concerned chemical into EU exceeding 1000 MT; 2013 between 100 MT & 1000 MT and 2018 for less than 100 MT.
- Pre-registration/Registration has to necessarily be done by a legal entity (Only Representative) in the EU OR an importer/distributor in the EU. Manufacturers/Exporters in India cannot do this unless they have an office which is a legal entity in the EU. In case pre-registration is not done, export to EU from January 2009 will not be possible without registration.
- There are consultants to provide this service to Indian exporters. You may also like to visit the Chemexcil website http://chemexcil-reachhelp.com for this purpose.
- A brief note may also be downloaded from http://plexcouncil.com/REACH/REACHConsultRecomm.pdf
- You may also like to download the guidance for monomers and polymers at http://reach.jrc.it/docs/guidance_document/polymers_en.pdf