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REACh
Registration, Evaluation, Authorisation of Chemicals

The European Regulation of chemicals came into force on 1 June 2007. Enterprises have to overtake more responsibility for a safer use of chemicals.
Thereby the disposal and recycling industry is also effected.

What is REACh’s target?
The new law entered into force on 1 June 2007 and changed the regulations for the use of chemicals.
Beside a registration requirement concerning certain substances, whose potential of damaging is especially high, the REACH Regulation gives greater responsibility to industry:
- They have to search data for the evaluation of the chemicals by themselves
- They have to manage the risks from chemicals
- They have to provide safety information on the substances for the next level of the supply chain.

Scope of the regulation
- Manufacturers and importers
 
Manufacturer: means any natural or legal person established within the Community who manufactures a substance within the Community; Importer: means any natural or legal person established within the Community who is responsible for import.
 
or
 
A natural or legal person established outside the Community who manufactures a substance on its own, in preparations or in articles, formulates a preparation or produces an article that is imported into the Community may by mutual agreement appoint a natural or legal person established in the Community to fulfil, as his only representative, the obligations on importers under this Title.

- who put substances or substances in preperation into circulation
 
Phase-in substance: means a substance which meets at least one of the following criteria:
 
(a) it is listed in the European Inventory of Existing Commercial Chemical Substances (EINECS);

(b) it was manufactured in the Community, or in the countries acceding to the European Union on 1 January 1995 or on 1 May 2004, but not placed on the market by the manufacturer or importer, at least once in the 15 years before the entry into force of this Regulation, provided the manufacturer or importer has documentary

(c) it was placed on the market in the Community, or in the countries acceding to the European Union on 1 January 1995 or on 1 May 2004, before entry into force of this Regulation by the manufacturer or importer and was considered as having been notified in accordance with the first indent of Article 8(1) of Directive 67/548/EEC but does not meet the definition of a polymer as set out in this Regulation, provided the manufacturer or importer has documentary evidence of this; evidence of this;  

All other substances are called non-phase-in substances.

in a volume more than 1 ton per year

The volume determines the duration of the transition period you can stretch through the pre-registration.
 
Transition periods regarding article 23 REACh-VO
 
volume                         period after entry into force;                    expiry date
 
More than 1.000 t/a       3,5 years                                           1 December 2010
 
CMR-substances
with more than 1 t/a       3,5 years                                           1 December 2010
 
Harzadous substances
with more than 100 t/a   3,5 years                                           1 December 2010
 
more than 100 t/a           6 years                                             1 June 2013
 
more than 1 t/a             11 years                                             1 June 2018
 

RIPs (REACH Implementation Project)
To develop, in close collaboration with all stakeholders, guidance helping to fulfil the
obligations under REACH.
 
RIP 1:             REACH Process Description;
RIP 2:             REACH – IT;
RIP 3:             Technical Guidance and Tools for Industry;
RIP 4:             Technical Guidance and Tools for Authorities;
RIP 5 & 6:     Setting up the Agency
RIP 7:             Preparation of the new tasks for the Commission More info: http://ecb.jrc.it/REACH/
 
The RIP 3 is most important for the SMEs
 
RIP 3.1:           Preparing Technical dossier
RIP 3.2:           Preparing CSA/CSR
RIP 3.3:           Information requirements
RIP 3.4:           Data sharing
RIP 3.5:           Down Stream User requirements
RIP 3.6:           C&L and GHS
RIP 3.7:           Application dossier
RIP3.8:            Requirements for articles
RIP 3.9:           Socio-Economic analyses
RIP 3.10:         Substance identity


Timeline
1 June 2009
Title applying:VIII - Restrictions
By 1 January 2009
Article 28(4) – European Chemicals Agency publish list of pre-registered substances on its website
By 1 June 2009
Article 58(3) – European Chemicals Agency’s first recommendation of priority substances to be included in Annex XIV (list of substances subject to authorisation).
From 1 June 2009 to 31 May 2013
Article 67 – compliance with existing Marketing and Use to restrictions for substances listed in Annex XVII.
By 1 June 2009
Article 67(3) – Commission to compile and publish an inventory of Annex XVII restrictions.
1 June 2009
Article 137(3) – Commission to incorporate into Annex XVII any amendments to Directive 76/769/EEC restrictions adopted from 1 June 2007.
1 June 2009 
Repeals of:
Directive 93/67/EEC (Risk assessment for new notified substances);
Directive 76/769/EEC (Restrictions on the marketing and use of certain dangerous substances and preparations).
1 June 2009
Annex XVII – List of restricted substances and conditions of restriction.
By 1 June 2010
Article 117(1) – First of 5-yearly MemberState reports to Commission on the operation of REACH.           
1 December 2010
Article 23(1) – registration provisions for phase-in substances for CMR (cat 1 or 2) and toxic (R50/53) over 1 tonne + per year, and other substances over 1000 tonnes per year.
1 December 2010
Article 116 – transitional arrangements for obligations in Article 113 to notify the Agency of substances subject to registration and/or dangerous substances classified as such under existing legislation.    
Who can give you a qualified support?
C&ERP provides professional consulting services regarding the regulations and creates an custom-made implementation plan. An individual contact person supports you with all administrative tasks and the whole compliance procedure. Count on the experts of all environmental regulations!


 
 
 
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