Are you ready for REACH

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• Are you ready for REACH?
• Flavie Guerin
• CS European Union
• Aquatech, October 2, 2008

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What is REACH?

• Registration, Evaluation, Authorization and
  Restriction of CHemicals

• REACH is the new EU chemicals regulation that
  became law in your countries on 1 June 07
• Implementation started in June 08 (ECHA set up)
• REACH is not just for the chemicals industry
• Sectors affected by REACH
• Environmental Technologies Aerospace
• ICT Textiles
• Automotive Cosmetics
• Energy power generation Medical
  Pharmaceutical

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What chemicals are covered?

• There is no list of chemicals covered by REACH
• All substances gt 1 ton are covered. There are few
  exemptions
• REACH applies to chemical substances on their
  own, in preparations (mixtures) and in articles
  (finished products)

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Substances and Preparations
Registration of substances in preparations
applies to every single substance gt 1 ton/year
Registration of substances gt 1 ton/year
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Articles

• Examples of articles (finished products) under
  REACH
• Rules applying to imported articles
• Products releasing a chemical registration of
  the substances intended to be released from the
  article
• Products containing substances of very high
  concern simple notification of the substance to
  the Agency

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REACH FAQ (1)

• FAQ Are my products covered by REACH?
• European Chemicals Agency Website (ECHA)
• REACH 101
• Guidance documents
• REACH Navigator (web-based tool to help determine
  REACH obligations free of charge)
• http//echa.europa.eu/
• Contact the U.S. Commercial Service (EU office)
• Counseling sessions, webinars, trainings
• List of REACH service providers
• Link to REACH websites (National helpdesks)
• http//www.buyusa.gov/europeanunion/reach.html

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REACH FAQ (2)

• FAQ How can I find an Only Representative?
• Non-EU based companies cannot directly (pre)-
  register . They have 3 options
• Registration by EU importers
• Establish an EU legal entity
• Or appoint an Only Representative (OR)
• The EU-based OR will do the (pre)-registration
  for the non-EU manufacturer
• Concerns about the cost and quality of ORs
• List of ORs on our website http//www.buyusa.gov/
  europeanunion/reach_bsp.html

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REACH FAQ (3)

• FAQ Is my substance on the Candidate List?
• Candidate List list of substances of very high
  concern
• The first Candidate List will be published in
  October 2008 on the ECHA website
  http//echa.europa.eu/chem_data_en.asp
• 1 substance has already been placed on the
  Candidate List triethyl arsenate (carcinogen)
• Watch for more (16 substances identified so far)
• Consequences of Candidate Listing
• Authorization required for the EU market
• Notification to the Agency of SVHCs in imported
  products
• Communication to customers and consumers

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REACH deadlines
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Dont miss the Dec. 1st deadline!

• Pre-registration

• Registration

• Deadline 1 December 08
• A simple postcard exercise (name of substance and
  volume)
• No fee
• Not mandatory but key to benefit from extended
  registration deadlines and secure continued
  exports

• Deadlines 2010, 2013, 2018 depending on volume
• Submission of a registration dossier (information
  on substances properties, uses, safe management).
  May involve testing.
• Registration fee (up to 1,200 Euros/ substance.
  SME reduction)

Pre-registration ends in 59 days
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REACH awareness is low

• A survey by PWC (Waking up to REACH) shows that
  REACH awareness is low, especially outside Europe
  and the chemicals industry
• This could lead to a ban on exports to the EU
• Pre-register your chemicals by Dec. 1st!

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• Thank you!