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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.

Hover your mouse over the action badges to get more detailed information.

The following scenarios have been developed keeping EU REACH compliance in mind. If you are a GB based company, UK REACH applies to you. Please see our Brexit webpage for more information. Our Gold subscribers can also access our helpdesk for both EU & UK REACH related enquires.

Your Situation  REACH Registration Needed? Chemical Safety Report Needed? Article Communication Required?  Safety Data Sheet Required?
I manufacture / import less than 1 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 1-10 tonnes of a substance each year Yes No. A CSR is not required for manufacture/import less than 10 tonnes per year. Not applicable Yes. Hazardous chemicals require SDS.
I manufacture / import more than 10 tonnes of a substance each year Yes. Yes. A CSR is 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 (1-10 tonnes per year) in the EU and export it outside the EU Yes. Registration is required even if not placing on the market in EU. No. If you manufacture less than 10 tonnes per year you will not need a CSR. Not applicable Yes. Hazardous chemicals require SDS.
I manufacture a substance (10 tonnes or more per year) in the EU and export it outside the EU Yes. Registration is required even if not placing on the market in EU. 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. Mixtures do not require exposure scenarios but you should use your suppliers’ exposure scenarios to pass safe use information for the mixture down the supply chain.
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 Required  Safety Data Sheet Required? 
I import cosmetic ingredients to make finished cosmetic products Yes. The cosmetic ingredients imported 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 No, registration not required for this use. 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, registration not required for this use. 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 pesticide active substances 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 Required  Safety Data Sheet 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 Yes. Hazardous chemicals require SDS.
I make finished goods (articles) in the EU and sell them into the EU A substance intended to be released from articles requires registration at 1 tonne or more per year if the substance has not already been registered for that use. If registration is required at 10 tonnes or more per year. Yes. If contains >0.1% by weight of an SVHC on the Candidate List. Notification to ECHA may apply. Not applicable
I make finished goods (articles) 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. If registration is required at 10 tonnes or more per year. Yes. If the article contains > 0.1% w/w of a substance in the candidate list, the EU importer needs to inform the recipient of the article. Notification to 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.

Sign up for our Gold service today and let our experts guide you though your business compliance for EU & UK REACH.

* for these situations there may be additional complications depending on your particular business context - contact our Helpdesk support

Become a REACHReady member - sign up now. Call us on +44 (0) 20 7901 1444 for more information. 

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