Since Regulation (EC) No 1907/2006 (REACH) entered into force in June 2007 manufacturers and importers of chemical substances in the European Union are obliged to register the substances manufactured or imported in quantities above 1 tonne per year until 31 May 2018 at the latest. But the 2018 deadline was not the end of the REACH story.
Nowadays, there are two major challenges for all actors after the initial registration duties are fulfilled,
- keeping the REACH registration dossiers up to date in a changing regulatory environment
- passing on and reflecting information throughout the entire supply chain
REACH requirements and processes can be overwhelming. spectra supports you with maintaining your REACH compliance or with registrations for new substances.
Compliance of your REACH registration
In 2018, the Commission, member states and ECHA have undertaken reviews of the operation of REACH and have derived certain conclusions and actions. The non-compliance of registration dossiers was identified as one major shortcoming that hampered the achievement of REACH objectives. Actions include both, increased number and extension of the scope of dossier checks by ECHA (completeness and compliance checks including Chemical Safety Reports, dossier evaluation) to improve the completeness and quality of registration dossiers.
spectra supports you with:
- checking the compliance of REACH dossiers
- updating dossiers (e.g. availability of new data, in case of tonnage band increases or upon request of ECHA)
- performing data gap analysis (e.g. for tonnage band updates)
- performing literature research (e.g. for data gap filling)
- developing testing or waiving/read-across strategies (e.g. (Q)SARs and other in silico methods)
- preparing or updating of Chemical Safety Reports (CSR) using CHESAR
Compliance throughout the supply chain
Since May 2018, all chemicals need to be either registered or exempted from REACH registration. Consequently, all actors in the supply chain are obliged to implement the information and conclusions to comply with the REACH dossier. This mainly concerns updating of SDS, implementing risk management measures for the registered uses and communicating this information throughout the supply chain. Thus, the focus of the enforcement authorities is now switching downwards from the manufacturers to the downstream users.
spectra supports you with:
- understanding the REACH process and the obligations for your company
- compliance check of your portfolio
- preparation for REACH audits
- review and possible update of classification and labelling of chemical substances and mixtures
- preparation of Downstream User Reports