REACH legislation in the European Union (EU) and its
implication on plastics
REACH is a European Community Regulation on chemicals and their safe
use. It deals with the Registration, Evaluation, Authorisation
and Restriction of Chemical substances. The new law entered into
force on 1 June 2007.
Download a brief on this regulation. Detailed information may be obtained
from
http://echa.europa.eu/home_en.asp.
A points to be noted are given below:
- Polymers are not covered under the REACH ambit. The EC regulation
clearly defines polymers. However, monomers in a polymer fall under REACH
and must be registered.
- Among the items that fall under our Council, masterbatches and the
ink used in writing instruments fall under ambit of REACH and therefore
exporters/manufacturers must take necessary action.
- With regard to other plastic processed goods (which possibly fall under
the "articles" as defined in the REACH regulation) - these are generally not
covered and a communication received from ECHA (the European Agency
monitoring REACH) against our query may be
viewed here.
- It is advisable that all chemicals falling under REACH (monomers,
chemicals in masterbatches, inks in writing instruments and other chemicals
in polymers) be pre-registered before December 1, 2008. Pre-registration is
a one-time facility offered by the European Commission till 1st December
2008 which will give a cushion to the registration.
- Registration is a more cumbersome process. The deadlines for
registration if pre-registered will be 2010 for imports of the concerned
chemical into EU exceeding 1000 MT; 2013 between 100 MT & 1000 MT and 2018
for less than 100 MT.
- Pre-registration/Registration has to necessarily be done by a legal
entity (Only Representative) in the EU OR an importer/distributor in the EU.
Manufacturers/Exporters in India cannot do this unless they have an office
which is a legal entity in the EU. In case pre-registration is not done,
export to EU from January 2009 will not be possible without registration.
- There are consultants to provide this service to Indian exporters.
You may also like to visit the Chemexcil website
http://chemexcil-reachhelp.com
for this purpose.
- A brief note may also be downloaded from
http://plexcouncil.com/REACH/REACHConsultRecomm.pdf
- You may also like to download the guidance for monomers and polymers
at
http://reach.jrc.it/docs/guidance_document/polymers_en.pdf