REACH Guide (May 07, last update Oct 2009)
1st May, 2008
This Orgalime guide is intended to provide practical guidance to downstream users using chemicals in their industrial (including engineering) processes as they prepare themselves to the new legislation. It is also addressed to producers and importers of articles. It does, however, not extensively address obligations of manufacturers or importers of chemicals, nor the obligations of formulators (“first level downstream users”).
The guide has been structured in a way that readers learn about REACH requirements in a progressive manner:
- Firstly, basic facts of REACH, main definitions and acronyms are explained to foster a common understanding of the information given in the guide, followed by an overview of important dates and deadlines.
- Secondly, the guide provides for four quick screens for engineering companies to identify in how far they are affected by the Regulation and the following requirements in particular: Registration of substances used in engineering processes - Registration of substances in articles - Notification of substances in articles and communication requirements - Authorisation of substances.
- Thirdly, issues of particular relevance to Orgalime industries are explained in more detail in individual guidelines. Also, links to other guidance documents provided by authorities or industry are compiled in the Orgalime guide to facilitate information gathering for engineering companies.
- The guide finishes off with a one page summary of REACH timelines and main obligations for Orgalime industries.
Since the previous update in May 2008, in particular REACH provisions on authorisation and restriction entered into force. Also, the Chemicals Agency (ECHA) has published further guidance documents and helping tools, and the Commission has issued additional information on REACH implementation.
This latest update mainly adjusts the following guidelines to the latest state of play:
- The guideline on requirements on authorisation (explanation on priority substances for inclusion in Annex XIV)
- The guideline on requirements on communication in supply chain
- The list of implementing measures, helpdesks and finalised ECHA guidance documents
Three new guidelines reflecting latest developments have been added on:
- the 'Substance Information Exchange Forum' (SIEF)
- the update of the candidate list (outline of the process for including new substances in the candidate list and obligations linked to the publication of the updated candidate list)
- Information requirements in the supply chain: Orgalime has developed a guideline on the implementation of Article 33 REACH down the supply chain and consumers as well as a model letter to facilitate communication between downstream users and recipients.
Personal electronic copy available for download at http://publications.orgalime.org.