reach compliance

 

CLP and REACH are the two most important chemical legislations in the EU communities and their scope is not limited to chemicals only. It is important that you comply with both legislation no matter whether you are an EU manufacturer/importer or a company who wishes to export your products to the EU communities.

 

REACH is the Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals. It came into force on 1 June 2007.

 

CLP stands for the Regulation (EC) No 1272/2008 on the Classification, Labeling and Packaging of substances and mixtures. CLP introduces the United Nations globally harmonized system (UN GHS) for classification and labeling of chemicals into Europe. CLP entered into force on 20th January 2009.

 

Substances, preparations ("mixtures") and articles have different obligations under REACH. Meanwhile, non-EU companies and EU companies have different obligations. Please find your obligations below.


  • non eu manufacturer
  • EU Manufacturer/Importer
  • article supplier and importer

Main obligations of non-EU manufacturers/exporters of chemicals under REACH&CLP:


Non-EU manufacturers do not have direct obligations under REACH&CLP. However, there are some issues non-EU manufacturers need to consider when they export their chemical products into the EU countries.

  1. Prior to export, non-EU companies need to pre-register or register their substance with the European Chemical Agency if the quantity of the substance exported into the EU exceeds 1 ton per year unless their importer has already per-registered /registered that substance;
  2. Non-EU companies generally need to appoint Only Representative to do the pre-registration/registration unless they have their own EU legal entities;
  3. First-time exporters of chemicals to the EU can check if you qualify for late pre-registration;
  4. Non-EU companies are required to provide Safety Data Sheets according to REACH and CLP standard at the first delivery of a substance or preparation if the substances or preparations meet the criteria for classification as dangerous;
  5. Non-EU companies may fulfill more obligations such as authorization and restriction under REACH.
  6. Please send your inquiry to info (at) cirs.ie if you are not sure about your obligations.

CIRS offers cost-effective REACH compliance services to non-EU chemical companies. If you are not sure about what to do to comply with REACH, please consult us for free advice.

Obligations of EU manufacturers/importers of chemicals:


Both REACH&CLP are targeted at EU manufacturers/importers. The following is a summary of obligations for EU manufacturers/importers.

  1. Prior to manufacture/import, M/I shall pre-register/register substances manufactured/imported over 1 ton per year with the European Chemical Agency (ECHA) under REACH;
  2. Importers will be exempt from REACH registration if their non-EU suppliers have registered; however, importers need to confirm with their suppliers' OR that they are on the inventory of importers and their tonnage and uses are covered by the OR. This can be done by asking for REACH Certificate of Compliance from the only representative of their suppliers every time before they put chemicals in the EU market.
  3. M/I can resort to third party representative for managing SIEF and finishing registration after pre-registration;
  4. M/I fulfill more obligations such as authorization and restriction under REACH;
  5. M/I of chemical substances or mixtures must classify, label and package these substances or mixtures in accordance with CLP, independently of the actual tonnage;
  6. M/I who place a hazardous substance on the market, have to notify certain information, in particular the substance identity and the classification and labeling of that substance to ECHA before 3 Jan 2010 under CLP
  7. M/I are required to provide Safety Data Sheets according to REACH and CLP standard at the first delivery of a substance or preparation if the substances or preparations meet the criteria for classification as dangerous;

CIRS offers cost-effective REACH compliance services to EU manufacturers and importers. If you are not sure about what to do to comply with REACH, please consult us for free advice.

Obligations of articles suppliers/importers under REACH:


Article is defined as an object which during production is given a special shape, surface or design, which determines its function to a greater degree that does its chemical composition. e.g. car, clothes, toys. Here articles suppliers mean non-EU article exporters and EU importers and producers of articles. Articles are subject to different provisions under REACH: Registration, notification, communication, authorization and restriction.

  1. Either article supplier or article importer has to register substances in articles if the substances are intended to be released during normal and reasonable foreseeable conditions of use and the total amount of the substance present in the articles with intended releases exceeds 1 tonne per year per producer or importer;
  2. Either article supplier or article importer has to notify any substances in articles to ECHA if the substance is identified as Substance of Very High Concerns (SVHC), the substance is present in all articles produced or imported by one actor in an amount totaling over 1 tonne per year and the substance is present in articles above a concentration of 0.1% weight by weight (w/w).;
  3. If an article contains SVHC in a concentration above 0.1% w/w, the supplier or importer of the article should ensure the safe use by: (a) Supplying the recipient of the article with sufficient information available to him, and as a minimum the name of the substance;(b) Providing the consumer with sufficient information available to him upon request in 45 days free of charge;
  4. Normally article producers shall try to avoid using any SVHC in their products and importer shall try not to buy any products that contain SVHC in a concentration above 0.1% w/w.
  5. Article suppliers or importers shall not produce or import any articles containing restricted substances unless authorization is granted.

CIRS offers full range of testing services including SVHC testing in China. If you or Chinese suppliers are not sure about what tests need to be carried out to your products to ensure they are safe and compliant with EU legislation, please consult us for free advice.