Are we complying with our obligations under the REACH Regulation?

Since the entry into force of REACH regulation a few years ago, manufacturers and suppliers were faced with the same doubts, What is REACH? , what do I have to register? How?

Before the panic sets in, let's stop and think about what the REACH, what I manufacture or sell, and what exactly obligations do I have to fulfill.

El REACH regulation o Regulation (EC) No. 1907/2006 of the European Parliament and of the Council of December 18, 2006 on the registration, evaluation, authorization and restriction of chemical substances and preparations (REACH), creating the European Chemical Substances and Preparations Agency was created to establish a new system for the control of chemical substances and mixtures that allows us to know both the hazardous characteristics of substances and the uses for which they are intended. This is an attempt to ensure greater protection of human health and the environment by minimizing the risks of exposure to them, and promoting the replacement of those that may be more harmful, such as the so-called CMR (carcinogenic, mutagenic and toxic to reproduction) and those that are bioaccumulative and/or persistent, with other less harmful ones.

The REACH Regulation affects manufacturers and importers of substances that are produced in quantities greater than 1 ton/year, who are required to register them.

To this end, registration deadlines were established depending on the type of substance and tonnage manufactured or imported, which are summarized as follows:

REGISTRATION DEADLINES

Until November 30, 2010— substances manufactured or imported in quantities equal to or greater than 1,000 tons/year- substances classified as CMR (carcinogenic, mutagenic or toxic to reproduction) manufactured or imported in quantities equal to or greater than 1 ton/year- substances that are very toxic to aquatic organisms that exceed 100 t/year.Until May 31, 2013— substances manufactured or imported in quantities equal to or greater than 100 t/year.Until May 31, 2018— substances manufactured or imported in quantities between 1 and 100 t/year

So we are still on time to comply with our obligations.

First of all, we must know what type of substances we handle because there are multiple exemptions to the norm and knowing them saves time and resources.

There is a long list of substances exempt from registration, including radioactive substances, already regulated by their specific legislation, substances under customs surveillance, medicines, foods or those included in annexes IV and V that, due to their characteristics and nature, their registration is considered unnecessary, among others.

Once we are clear about the substances we need to register, we must proceed to collect all the information available about them, since the registration involves the creation of a dossier where all the information relating to the identity of the substances, and their physico-chemical, toxicological and ecotoxicological properties, is collected.

This process can be tedious and can generate all kinds of doubts and this can lead us to leave “everything to the end”, so good advice can facilitate this process. We still have time, so let's get to work.