What is REACH?

REACH stands for Registration, Evaluation and Authorisation of Chemicals. Its aims to ensure an improvement in health of people and the environment, whilst at the same time not inhibiting competitiveness, innovation, and the free movement of substances which contain chemicals or where chemicals were involved in their production.

A tall order! The creators of the regulation also stated that they hoped REACH would provide more knowledge and information about chemical substances in everyday products. It is also to promote alternative methods of testing – including a reduction of animal testing – and to encourage greater responsibility on the part of those who manufacture and distribute goods with a chemical content.

Are you beginning to see where we as manufacturers and retailers fit in?

Our responsibilities

REACH imposes a number of obligations on affected parties, and a body which will oversee the running of these has been established in Helsinki. It will become fully operational on 1 June 2008.

As manufacturers and retailers we tend to come under the description of “downstream users” of substances covered by REACH. There are two key issues for us: registration and notification of substances in articles, and a duty to communicate information on substances in articles.

It is not possible in this short article to go into detail of these requirements, but suffice to say that the intention of the new legislation is the registration of all chemical substances present in the EU in volumes larger than one tonne. Similarly, substances defined as “Substances of Very High Concern” (SVHCs) have to be brought to the attention of the body implementing this legislation.

In practice, once 'candidate lists' of chemicals are published, manufacturers, importers, and even some users and distributors will have to be able to produce information, such as the identity of the producer or importer, a registration number if available, and a description of the substance, including a description of its use and the volume/quantity involved.

Practical problems

There are already a number of practical problems emerging.

For example, it would appear that the obligation to notify and communicate information will start as soon as the first 'candidate list' appears, which seems unrealistic given that “downstream users” may have to seek information as to whether any of these substances involve them. Moreover, suppliers have to give information to the recipient of the product at the time of delivery; there is some confusion as to whether service manuals can be used or whether REACH information should be issued separately (and kept for the required ten years).

Note also that suppliers are obliged to give information to a consumer within 45 days of receipt of a request. Not surprisingly AMDEA is looking closely at how our members and their trade partners might be affected. As part of our European Trade Association CECED, we are reviewing the substances likely to be found in the processes and products of the domestic appliance industry. We are encouraging our members to compile a 'substance inventory list' and to start a dialogue with their suppliers.

We all need to learn to live and work with REACH, since non-compliance will result in sanctions. Moreover, if a supplier was found not complying with REACH, this could leave manufacturers and distributors with problems, such as lack of products or parts. And of course, the company reputation could be at risk if it was dealing with parties which are perceived to be failing to take their responsibilities seriously when dealing with chemicals.

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