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Should you worry about Reach?

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Many of our subscribers ask us if they are affected by REACH and the short answer is normally “Yes”.

But how worried should you be about the amount of work you must do? We've developed this tool to help you decide.

The happier the face, the happier you’ll be too. Hover your mouse over the people to get more detailed information.

Your Situation  REACH Registration Needed?
 		Chemical Safety Report Needed?
 		Article Communication & Notification Required?  Safety Data Sheet / Exposure Scenarios Required?
I manufacture / import less than one tonne of a substance each year
 No. There is no need to register.
 No. There is no need to register.
 Not applicable. Yes. Hazardous chemicals require SDS.
I manufacture / import more than one tonne of a substance each year Yes
 Yes. A CSR required for manufacture/import over 10 tonnes per year. Not applicable Yes. Hazardous chemicals require SDS. Additionally, hazardous substances registered at 10 tonnes or more per year require Exposure Scenarios.
I manufacture a substance (one tonne or more per year) in the EU and export it outside the EU Yes
 Yes. If you manufacture 10 tonnes or more per year you will need a CSR. Not applicable Yes. Hazardous chemicals require SDS. Additionally, hazardous substances registered at 10 tonnes or more per year require Exposure Scenarios.
I buy in a substance from EU suppliers who have REACH registered and I make mixtures No. No. However, if your use has not been included by your supplier you may need to prepare your own CSR.
 Not applicable Yes. Hazardous chemicals require SDS. Additionally, hazardous substances registered at 10 tonnes or more per year require
I buy in a substance that is REACH registered and I make articles No. No. However, if your use has not been included by your supplier you may need to prepare your own CSR. Yes, but only if the article contains a substance on the Candidate List above 0.1% by weight. No. A SDS is not required for finished goods.
I use chemicals and buy from EU sources No. Registration may be required by your EU supplier. No. However, if your use has not been included by your supplier you may need to prepare your own CSR. Not applicable unless you produce articles containing Candidate List substances above 0.1% by weight. Yes. Hazardous chemicals require SDS. Additionally, hazardous substances registered at 10 tonnes or more per year require Exposure Scenarios.
Your Situation REACH Registration Needed?  Chemical Safety Report Needed?  Article Communication & Notification Required  Safety Data Sheet / Exposure Scenarios Required? 
I import cosmetic ingredients to make finished cosmetic products Yes. The cosmetic ingredients impoted at 1 tonne or more per year need to be registered.
 Yes. Only for ingredients manufactured/imported in over 10 tonnes per year. However, the CSR need not contain consideration of the risk to human health.
 No
 Yes. Hazardous chemicals require SDS. Additionally, hazardous substances registered at 10 tonnes or more per year require Exposure Scenarios. However, SDS requirements do not apply to cosmetic products which are mixtures in the finished state intended for the final user.
I import essential oils and sell to the food industry as additives No. Registration not required for this use
 Not applicable.
 Not applicable
 Yes. Hazardous chemicals require SDS. However, SDS requirements do not apply to mixtures for food use which are in the finished state intended for the final user.
I import cosmetics in their finished form Yes. The cosmetic ingredients imported at 1 tonne or more per year need to be registered.
 Yes. For all components subject to registration, though the CSR need not include risks to human health
 No
 No. SDS requirements do not apply to cosmetic mixtures which are in the finished state intended for the final user.
I make food additives and export outside the EU
 No. Registration not required for this use
 No
 Not applicable
 Yes. Hazarous substances require SDS. However, SDS requirements do not apply to mixtures for food use which are in their finished state intended for the final user.
I import polymers Yes. The monomers and chemicals making up >2% and 1 tonne or more per year have to be registered.
 Limited to the monomer and chemical components where 10 tonnes or more per year.
 Yes. If the polymer is an article (for example a plastic film or bag) and it contains Candidate List substances communication and notification may be required.
 Yes, but limited to polymer
I make surfactants that go into pesticide formulations and other uses.* Yes. Registration is required for manufacture of 1 tonne or more per year, but not for pesticide use covered by Directive 91/414/EC.
 Yes. A CSR is required for registration at 10 tonnes or more per year, but not for pesticide uses covered by Directive 91/414/EC.
 Not applicable
 Yes. Hazardous chemicals require SDS.

Your Situation REACH Registration Needed?  Chemical Safety Report Needed?  Article Communication & Notification Required  Safety Data Sheet / Exposure Scenarios Required? 
I make pesticide active ingredients for export
 Yes, if not registered as pesticide in EU
 Yes, but only for EU exposure
 Not applicable
 Yes. Hazardous chemicals require SDS.
I make a series of intermediates as part of the chemical process Yes. Limited requirements depending on type of intermediate and if under strictly controlled conditions.
 No. CSR not required
 Not applicable
 Yes. If supplied, hazardous chemicals require SDS.
I buy or sell intermediates as part of manufacturing No. Not if your supplier has already registered the intermediate
 No. CSR not required, but need to confirm use under strictly controlled conditions Not applicable
 es. Hazardous chemicals require SDS.
I make finished goods in the EU and sell them into the EU No. As long as the substance has already been registered in your supply chain for that use. No, unless registration at 10 tonnes or more per year is required.
 Yes. If contains >0.1% by weight of an SVHC on the Candidate List.
 Not applicable
I make finished goods outside the EU and export them to the EU * Yes. Substances that are intended to be released from the articles may require registration by your EU importers if imported at 1 tonne or more per year and not already registered further up the supply chain for that use.
 No
 Yes. If the article contains >0.1% w/w of a substance on the Candidate List duties to tell your customers and notify ECHA may apply
 Not applicable
I make chemicals that go solely into medicinal or veterinary products No. Registration not required for this use
 Not for these uses.
 Not applicable
 Yes. Hazardous chemicals require SDS. However, SDS requirements do not apply to medicinal mixtures for human and veterinary use which are in the finished state intended for the final user.
I buy in waste and scrap, recover, recycle or reprocess it and sell it on Yes. If the substance you sell on is not the same as the one that has already been registered by someone else you may need to register.
 Yes. If registration is required at 10 tonnes or more per year.
 No
 Yes. Hazardous chemicals require SDS. Additionally, hazardous substances registered at 10 tonnes or more per year require Exposure Scenarios.

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Silverbear Event Listing


09 Dec 2020

CLP Poison Centre notification requirements

Aimed at business, regulatory managers and practitioners working in companies that will need to notify mixtures they place on the market. The programme is ideal for anyone who needs to understand more about their obligations under the new Annex VIII of the Classification, Labelling, and Packaging (CLP) Regulations.  

***This workshop will be delivered via a web-based environment and split over 2 half day sessions - am Wednesday 9th December and am Thursday 10th December***

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