We are your partner for REACH Compliance
REACH consultancy
At REACh ChemConsult GmbH, we provide advice and training on all REACH related matters for our customers. Let the professionals advise you! We have been advising on REACH since 2007.
The EU regulatory framework REACH (Registration, Evaluation, Authorisation of Chemicals) entered into force on 1 June 2007. REACH Regulation (EC) No 1907/2006 affects ‘new’ and ‘existing’ substances. Manufacturers and importers of existing chemicals (phase-in substances = normally on the market before September 1981) are enforced to register all chemicals of a production volume exceeding 1 t/a. Each registration submission will consist of a Technical Dossier and, for substances above 10 tonnes, a Chemical Safety Report (CSR). Failure to register will mean that the substance cannot be manufactured or imported (no data no market).
Chemicals had to be regularly preregistered from June 01, 2008 to December 01, 2008. Later on a late pre-registration was possible according to paragraph 6 of Article 28. Basic information such as the chemical name, CAS number and production volume were required and needed to be submitted to the European Chemicals Agency (ECHA) for the pre-registration.
The deadline for registration was depending on the yearly production level and the toxicity of the substances. The timelines for the registrations are summarised in the following table.
tonnes/year |
timelines for registration |
>1000 |
before December 01, 2010 |
>1 und CMR (Carcinogenic Mutagenic or Reprotoxic) |
before December 01, 2010 |
>100 und R50/53 (dangerous for the aquatic environment) |
before December 01, 2010 |
100-1000 |
before June 01, 2013 |
1-100 |
before June 01, 2018 |
Now, for any registration an inquiry must be submitted to ECHA first. We would be happy to prepare this enquiry for you at ECHA.
Some substances of very high concern (SVHC) need to be authorised for their use and their placing on the market. SVHC subject to authorisation will be put into Annex XIV of REACH following a decision by the European Commision.
Substances reqiured to be authorised are substances meeting the criteria for classification as carcinogenic or mutagenic or toxic for reproduction category 1 or 2 (CMR) or substances which are persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB). Further, substances causing probable serious effects to humans or the environment equal to those above, such as endocrine disrupters are required to be authorised.
For SVHC substances that are contained in articles to more than 0.1 per cent by mass, the recipient must be informed in accordance with Article 33 of the REACH Regulation. The Waste Framework Directive and, under certain conditions, Article 7 of the REACH Regulation stipulate that such substances must be notified to ECHA. The procedure is called SCIP notification (Waste Framework Directive) or notification of substances in articles (REACH Art. 7 (2)). We can carry out the SCIP notification for you as well as the notification to ECHA in accordance with REACH.
The results obtained from the REACH registration of substances are incorporated into the safety data sheet. We prepare safety data sheets in all EU languages and also worldwide as your external consultant.
We are happy to support you with inquiries, the registration or authorisation of your substances, with your duties as producer of articles or with a REACH conformity check: our services in the context of the REACH regulation. The experienced team at REACh ChemConsult GmbH is at your side for all matters relating to REACH. Give us a call or email us if you have questions or are interested in our service. We look forward to hearing from you.