Initially conceived to promote the human and environmental impact of substances, preparations and articles, REACH has been harmonized with CLP (Classification, Labeling and Packaging) to create a complete risk & hazard based regulation.

Now that the first major deadline has been passed, the scale of this directive can be assessed. Since its inception in October 2008, there have been 2.7 million pre-registrations by over 200,000 entities. Despite this huge number of pre-registration (which was fifteen times great than the European Chemical Agency (ECHA) expected), only 10% of legal entities followed through full registration by the 1st December 2010 deadline. 87% of these registrations were carried out by large enterprises, leaving the balance to be completed by Small to Medium size Enterprises (SME’s). The effects outside of Europe were also significant, with 19% of registrations coming from Only Representatives (OR’s – responsible for registering on behalf of non-European companies).

In light of these figures which highlight the underestimated compliance with REACH, ECHA has begun the process of Dissemination of Data accrued from the registration dossiers. This was one of the main intentions of REACH, providing free and easy access to basic data on substances collected in its databases, including information on their intrinsic properties, hazard profiles, classification and labeling, authorised uses and risk management measures associated with them. Due to the larger than anticipated number of registrations, this process was slow to start, but as of July 2011, 3,411 substances have had their information disseminated.

Another important consideration is the continuing expansion of the ‘Candidate List’. Since being published in October 2008, the list has been expanded from 15 to 53 substances (as of 20th June 2011). Substances on the Candidate List require authorisation prior to use, they can be found here.

SIP has successfully fulfilled the obligations of REACH, and all of its products are registered for their appropriate use within Europe. Despite this success, REACH will always be a vital consideration to European trade, and SIP will continue to work with its customers to ensure that information is passed smoothly along the supply chain and that new products can be easily bought to market. Any queries pertaining to REACH will happily be answered by SIP’s REACH Implementation Team.

Important dates in the REACh timeline:

  • ­1st January, 2009 – list of pre-registered substances and SIEF’s are published
  • 1st December, 2010 – end of the first phase-in period. The following pre-registered products must be registered:
    • products produced or imported in excess of 1000 Mt/annum
    • substance produced in excess of 100 Mt/annum that are classified as very toxic to marine organisms
    • substances produced in excess of 1Mt/annum that are classified as category 1 or 2 CMR’s (Carcinogenic, Mutagenic or Reproductive toxicants).
  • 1st June, 2013 – end of second phase-in period. Any substance produced or imported in excess of 100 Mt/annum must be registered.
  • 1st June, 2018 – end of the last phase-in period. Any substance produced or imported in excess of 1 Mt/annum must be registered.