In last week’s post, we reviewed REACH and an overview of the number of chemicals/substances regulated by REACH. This week, we will go into additional details on the impact of the regulation.

A central point of REACH is that it does not just impact or restrict itself to the chemical industry. The regulation is designed to improve/reduce the environmental impact of all products from the manufacture, transportation, import, export, sale, use and ultimately disposal or recycling phase of a product. In other words, producers, distributors, retailers and consumers must be concerned about the environmental impact of everything they produce, sell or use through a products entire lifecycle.

REACH regulates almost all substances manufactured or imported into the EU market above one ton per year. If a product contains a Substances of Very High Concern (SVHC), it will require some form of Reporting, Registration or Authorisation to be sold in the EU market. Simply put – no data/no market. You must know what is in your product to determine which if any of the regulations apply. For REACH SVHC compliance alone, there are seven different lists with a variety of requirements, recommendations and interconnections as part of the process. 

  • Registry of Intention (RoI): This list consists of three subset lists: Harmonized, Classification and Labeling (HCL), SVHC, and Restriction Intentions.
  • Proposed SVHC List or Public Activities Coordination Tool (PACT): PACT risk management option analysis = risk management option analysis (RMOA). This is a list of substances for which a RMOA or an informal hazard assessment for persistent, bio accumulative and toxic/very persistent and very bio accumulative or endocrine disruptor properties (PBT/vPvB) is either under development or has been completed since the implementation of the SVHC Roadmap to 2020 commenced in February 2013. The list is updated monthly to show the new substances selected by authorities for RMOA or hazard assessment and to inform the public of the outcome of these preparatory steps and the follow-up steps recommended.
  • SVHC Candidate List: The SVHC substances selected for review as potentially toxic. 
  • Prioritization List: This list changes based on European Chemicals Agency (ECHA) recommendations for inclusion on the SVHC Candidate List or Restriction List. Priority primarily assigned based on the volumes of the in-scope substances on the EU market.  A search of the ECHA website referring to Article 57 should provide latest substances submitted to ECHA for review.
  • Authorization List: Also known as the REACH Annex XIV, the list contains substances subject to authorization under EU REACH regulation. The substances on this list are selected from REACH SVHC list and cannot be placed on the market or used after a specific “sunset date.” 
  • Community rolling action plan (CoRAP) List: The list is a rolling two year action plan list of substances.
  • Restriction Substances List (RSL): Section 8 of REACH details the restriction on certain dangerous substances and preparations or articles which are manufactured, used and placed on the EU market. Any substance could be restricted in EU if the use of the substance poses an unacceptable risk to human health or the environment. Currently, the list contains 59 categories of restricted substances in REACH Annex XVII with more than 1000 individually identified substances. See links below for more details on the regulations this has replaced and the substances included.

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