Advice on REACH - Identification of the legislative obligations of a company to REACH

Lars-Henrik Lau Heckmann

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Advice on REACH - Identification of the legislative obligations of a company to REACH

It can be a daunting task to both identify the role or roles of a manufacturer in the supply chain and be able to comply with the legislative requirements of REACH.

The demands of REACH on a manufacturer depend on the following:

a. Whether the product is a clean chemical substance, a chemical mixture or an article
b. The position of the manufacturer in the supply chain
c. The degree of danger in the product’s chemical composition
d. The amount of the dangerous chemical(s) in the product

Danish Technological Institute can offer advice on and identification of the duties and obligations imposed by REACH
What does REACH mean to a company, manufacturer or business?

It means that:

  • All businesses that produce, import (to the EU) or use chemicals in amounts > 1 tonne/year must comply with REACH
  • Importers (to the EU) and dealers of articles which contain > 0.1 weight % of extremely problematic substances are also subject to REACH

An article is defined as: An item, which via the production process gradually acquires its shape, texture and design, all of which have a greater impact on the function of the item than its chemical composition – in other words, goods in general.

Specific problematic substances are: carcinogens, substances that can be damaging to genetic inheritance (DNA), can impair reproduction, and /or disrupt the hormones – all are included in REACH’s list of substances for regulation.