Our experts at WSP Environmental have outlined five key steps to making sure your business is prepared for REACH. Click to to reveal our advice:
Your first series of questions will involve looking at any obligations you may have to register substances you manufacture or import under REACH. This is an important exercise as failing to spot chemicals at this stage may lead to you missing the essential pre-registration deadline in 2008. Remember that if you import mixtures of chemicals e.g. in the form of paints, you will have to think about each and every chemical in that mixture.
Pre-registering a chemical under REACH in 2008 will be comparatively straightforward and inexpensive. Taking a chemical forward to full Registration could be very expensive depending on the tonnage produced and the amount of data already available. If it is a fairly high tonnage chemical and there is little information available then you have to question whether it will be worth you continuing to manufacture or import that chemical as filling in the data gaps may be an expensive process, outweighing any likely profits. If there are co-producers of the same chemical then there will be possibilities of sharing the testing costs with them.
The pre-registration window open from June to November 2008 is an important time for anyone who manufactures or imports substances. Pre-registration will be a comparatively straightforward procedure but if you miss this deadline then you have to register your chemical immediately rather than wait until the tonnage registration deadlines. Pre-registration therefore effectively buys you time before having to fully register your substances.
If you use rather than manufacture or import chemicals then you need to assess how vulnerable you are to certain of your raw materials disappearing from the market. Some suppliers may decide that it is not financially viable for them to take those raw materials through REACH. It will be important for you to get as much warning as possible to this happening. WSP Environmental has developed a REACH Vulnerability Assessment tool specifically to help in this assessment.
REACH will require manufacturers and downstream users of chemicals to communicate information up and down the supply chain. Manufacturers will need to register the ‘use’ of their chemicals which can naturally only be done if they have information from the downstream user as to the use of that substance. It is essential therefore that downstream users of chemicals ensure that the suppliers are aware of their use and are intending to register that use.
About REACH 