Complying with REACH in chemicals manufacturing
If you use or manufacture chemical substances, or import them from outside the European Union (EU), you must comply with the REACH (Registration, Evaluation, Authorisation and restriction of Chemicals) Regulation.
The UK REACH Competent Authority is hosted by the Health and Safety Executive (HSE).
REACH applies to a very wide range of chemical substances, either on their own or in preparations and mixtures.
Preparations and mixtures include:
- coatings eg paints, varnishes or enamels
- pigments, dyes or inks
- cleaning products
- photograph processing chemicals
- chemicals used to produce man-made fibres.
REACH also applies to any chemical substances contained in any finished products or articles, whether you are manufacturing or supplying them within the EU, or importing from outside the EU.
UK REACH Competent Authority: What REACH means for EU importers (Adobe PDF - 221KB)
UK REACH Competent Authority: REACH guidance on articles (Adobe PDF - 110KB)
Manufacturers and importers
If you manufacture or import into the EU one tonne or more of a chemical substance in a calendar year, you must register the substance with the European Chemicals Agency (ECHA).
Registration
If it is the first time you are manufacturing or importing one tonne or more of a chemical substance within a calendar year and you are unable to make a late pre-registration, you should register at least 21 days before you start to manufacture or import the substances.
ECHA: Guidance on registration (Adobe PDF - 1.36MB)
The ECHA has a website which you can use to register any chemicals online. You can also use the website to submit data and other information.
ECHA:REACH-IT
If you manufacture or import into the EU more than 10 tonnes of a chemical substance in a year, you may need to carry out a chemical safety assessment. You must produce a chemical safety report to show the results of your assessment. You must submit this report to the ECHA as part of your registration application.
ECHA: Information requirements and chemical safety assessments (Adobe PDF - 303KB)
Pre-registration
Pre-registration has now closed. You can only make a late pre-registration if you are manufacturing or importing into the EU one tonne or more of a phase-in substance in a calendar year for the first time. You must be able to provide evidence for this.
If this applies to you, you must pre-register:
- no more than six months after you begin to manufacture or import the substance and
- at least one year before the ECHA registration deadline for the quantity and type of your chemical.
If you pre-registered any phase-in substances before 1 December 2008 you will still have to complete a full registration with the ECHA. The deadline for your registration will depend on the quantities of chemicals you handle and in some cases whether they have certain hazardous properties. You will have submitted a proposed registration deadline as a part of your pre-registration.
The ECHA has produced a questions and answers document covering pre-registration.
ECHA: REACH pre-registration – Questions and answers (Adobe PDF - 1.45MB)
Substance Information Exchange Forums (SIEFs)
Under REACH, Substance Information Exchange Forums (SIEFs) are being created so that businesses that have pre-registered the same chemical can share information. You will be able to use SIEFs to make joint registrations. You are automatically added to a SIEF when you pre-register.
ECHA: Substance Information Exchange Forum
Exempt substances
Some chemical substances are partially or completely exempt from REACH. See the UK REACH Competent Authority guidance for further information about exemptions. Be aware that exemptions may change.
UK REACH Competent Authority: REACH – exemptions (Adobe PDF - 123KB)
Retailers and distributors
If you are a chemical retailer or distributor you also have a role to play in REACH.
UK REACH Competent Authority: The distributors role in REACH (Adobe PDF - 96KB)
You should make an inventory or list of chemical substances that your business uses, manufactures or imports. This will help you understand your responsibilities, what you need to do and the impacts REACH will have on your business activities.
UK REACH Competent Authority: Creating an inventory for downstream users of chemicals including formulators (Adobe PDF - 111KB)
You must also comply with any marketing and use restrictions that have been placed on chemicals you sell or distribute.
Users of chemicals
You are a user if you:
- use any chemicals or preparations
- make chemical preparations yourself
- use any chemicals or preparations to produce articles.
If you use a chemical substance you must make sure that:
- when you use the chemical you apply any safety measures identified by the chemical's safety data sheet, if one is required
- you use the substance within its safe exposure limits
- you comply with any restrictions that have been placed on its use.
Substances of very high concern (SVHCs)
REACH identifies substances with known high risks to human health or the environment as substances of very high concern. These include substances that are classified as persistent, bioaccumulative and toxic (PBT) in the environment.
The ECHA has produced a proposed candidate list of possible substances of very high concern.
ECHA: Candidate list of substances of very high concern for authorisation
The UK REACH competent authority has produced guidance on substances of very high concern.
UK REACH Competent Authority: Substances of very high concern (Adobe PDF - 94 KB)
Provide information
You should speak to your suppliers and make sure they register all the ways you use the chemicals they supply. This is to make sure that your supply of chemicals will not be disrupted.
If you have an unusual use for a substance, you should provide your suppliers with details of how you intend to use the chemical. This will allow them to include this information in their registration.
You can choose not to give your suppliers this information if you feel it will compromise your business. In this case you must carry out your own chemical safety assessment. You must provide this information to the ECHA and downstream users.
ECHA: Chemical safety assessment and report
ECHA: Guidance in a nutshell - chemical safety assessment (Adobe PDF - 173KB)
Restricted chemicals
REACH places restrictions on the marketing and use of certain chemical substances and preparations. Restrictions are placed on chemicals when they are shown to cause harm to human health or to the environment.
Annex 17 (XVII) of the REACH regulation contains a list of restricted chemicals with the associated restrictions and concentration limits. The list of chemicals and restrictions may be added to.
Restricted chemicals include:
- lead carbons
- lead sulphates
- benzene
- pentachlorophenol
- nonylphenol and its ethoxylates
- cadmium
- hexachloroethane
- creosote
- compounds containing mercury and arsenic.
EC Regulation: Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Annex XVII (Adobe PDF - 1.78MB)
If a chemical is listed in annex 17 (XVII) you must not:
- market or use the chemical for the restrictions outlined
- market or use any substances, preparations or article containing the chemical for the restrictions outlined
- allow or cause anyone else to break the rules of a restriction.
Annex 17 (XVII) chemicals are restricted to protect:
- workers
- consumers
- the environment.
Different regulators enforce the restrictions depending on the chemical and part of the UK you operate in. To check any chemical and the restrictions on it, contact the HSE to find out which regulator you need to speak to.
Health and Safety Executive: REACH helpdesk
