The European Union’s REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) regulation requires all companies manufacturing, importing, distributing, or using chemical substances in Europe to examine their chemical inventory for substances within the scope of the regulation and to ensure compliance.
The European Chemicals Agency (ECHA) manages the system. Key components of REACH include:
- registration of manufactured/imported chemical substances
- increased information and communication throughout the supply chain
- evaluation of certain registered substances
- authorization for use of substances of very high concern
- restrictions of certain substances for specific uses
Understanding the scope of REACH
Risk professionals can develop a better understanding of a company’s total product risk profile by conducting a thorough analysis of the company’s product safety compliance program, including product life cycle and supply chain. That analysis should now take REACH regulations into account.
Such an analysis, however, can be a complex undertaking, as the scope of REACH is vast and several issues could affect a company’s ability to meet its obligations under the regulation. If a company is unable to meet its obligations, it risks penalties or exclusion as a supplier.
Conforming to REACH can be time-consuming and cumbersome, in part because non-European or smaller European manufacturers or importers often don’t have the resources to support their European importers’ compliance with the regulation. Importers need to know the background of each substance used in their products, including European hazard classification and other information included in the safety data sheet. Given the wide scope of the regulation, REACH has a huge impact on the supply chain.
In the past, U.S. regulatory bodies allowed manufacturers to claim “proprietary information” when completing forms. But that’s unacceptable under REACH, which requires manufacturers to provide detailed information regarding the composition of all chemicals. In other words, no company may import a substance within the scope of REACH without registering it.
It’s critical that companies have comprehensive REACH compliance programs in place, because achieving compliance can help mitigate corporate risk and protect the corporate brand. Conversely, noncompliance can result in significant repercussions, including fines and damage to the brand.
Managing REACH obligations
Key risk evaluators in property/casualty insurance organizations can facilitate enhanced compliance with REACH by encouraging client executives and directors to research and apply global regulatory compliance processes, content and information, technology platforms and applications, and activities and tasks associated with delivering REACH compliance.
Companies affected by REACH should seek assistance from providers well-versed in environmental health and safety (EH&S) regulations and the EU regulatory environment. 3E Company’s tools and services support multiple REACH requirements, including identification and categorization of substances, volume tracking, authoring of extended Material Safety Data Sheets (MSDS), downstream supply chain communications with MSDS distribution services, and other outsourced registration-related REACH services.
3E Company has spent more than two decades helping customers understand chemical, regulatory, and compliance management. Data and professional expertise are at the very core of all the products and services 3E Company delivers. REACH compliance is no exception. 3E Company offers a unique combination of tools and services that can help companies with the preparation process and with ongoing compliance. For more information, please visit www.3ecompany.com.