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Environmental Law Firm Releases REACH Document

White & Case LLP has published a Q&A document about the European Union's Registration, Evaluation and Authorization of Chemicals (REACH) legislation, which goes into effect on June 1, 2007.
The document — Europe's New Chemicals Legislation Has Worldwide REACH — responds to key questions that many electronics companies have about the chemicals legislation including what types of chemicals are covered by the regulation, and who is responsible for complying. It also discusses the first REACH obligation of pre-registration, along with registration requirements and deadlines.
Excerpt from Europe's New Chemicals Legislation Has Worldwide REACH as below:
Q1.Does REACH apply to all types of chemicals? A1.REACH applies to all substances manufactured, imported or used in the EU, irrespective of whether or not they are classified as dangerous.
Q2.Who will be responsible for complying with REACH? A2.Duties under REACH will depend on the operator's role in the supply chain of each substance. Broadly speaking, REACH applies both to European manufacturers of substances, preparations or, under some conditions, articles, and to European importers of substances, preparations and articles produced in third countries. Although REACH does not apply directly to US or Asian manufacturers of substances or articles, those manufacturers will still have to provide their importers in Europe with detailed information on the substances they supply or use to make their products.
Q3.What types of obligations will they get? A3.REACH creates a general obligation for EU manufacturers and importers or EU-based representatives of a non-EU manufacturer to register each substance manufactured or imported into the EU in volumes of one tpy or more with a new body, the European Chemicals Agency (ECA), which will be up and running by June 2008, and will be generally responsible for handling and supervising all the formalities arising under REACH. We're talking about nearly 30,000 chemicals — and any substance or use of a substance not registered will be banned throughout the EU — no data, no marketing.
Q4.What are the registration deadlines? A4.The first REACH obligation is the pre-registration between June 1 and December 1, 2008 of all existing substances listed in the European Inventory of Existing Commercial Chemical Substances (EINECS) — also referred to as "phase-in" substances — manufactured or imported in quantities of one tpy and more. Following pre-registration, registration deadlines apply on December 1, 2010, June 1, 2013 and June 1, 2018, depending on the tonnage band and level of concern of the substance. Non phase-in substances — that is, those  not produced or marketed before REACH's entry into force, must be registered before being placed on the market. Registration starts on June 1, 2008.
Q5.Is registration the end of the story? A5.It's just the beginning — the ECA will only check that the information required on a chemical substance is available in the registration dossier. The next stage is evaluation, which constitutes a check of quality. The ECA will verify that the contents of the registration dossier comply with the registration requirements, and will check the proposals for testing submitted as part of a registration before tests are performed — this is called the "dossier evaluation."
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