REACH tasks of manufacturers of articles

REACH notification


According to REACH requirements, a targeted analysis should only be conducted as a last resort in order to identify whether substances of very high concern are present in articles.


The Service includes:



reach szolgáltatásConducting analyses to identify whether substances of very high concern are present in your articles
reach szolgáltatásAssistance in choosing the laboratory for article testing
reach szolgáltatásAccording to the laboratory report, determining if any high concern substance reach the 0.1 w/w % in your products
reach szolgáltatásProviding strategic advice in order to reduce the risks of substances of high concern in the article
reach szolgáltatásPreparing the dossier for notification of substances of high concern, as requested in 2011

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Manufacturers of articles may have three important tasks:


1. Pre-Registration, Registration



Pre-registration or registration is only required if, among normal circumstances of using the article, a chemical substance can intentionally enter the environment, and this chemical substance is present in the given articles at quantities exceeding 1 ton per year. To illustrate this with an example, a scented eraser is an article where the chemical substance (perfume) enters the environment during the usage of the article. If this eraser is sold in a quantity that results in the possibility of 1 ton of perfumed chemical substance entering the environment per year, then the perfume substance must be registered.
If you are impacted by this section, please read the registration part of my website.


2. Notification requirement


Notification requirement and registration requirement are two different tasks. You have a notification requirement to the European Chemical Agency, if any candidate listed substance can be found in the given article at a quantity exceeding 1 ton, and at a weight concentration exceeding 0.1 percent. The first notification deadline is 1 June 2011. By this date the company should prepare an agenda of how it will test the presence of the candidate listed substances in its end products. I would like to emphasize that the 0.1 weight percentage is calculated for the entire article and not its components.

If you have a candidate listed chemical substance in your article, then your best choice is to replace this substance with a less hazardous chemical substance by latest 1 June 2011.

You can find the candidate list at the following link:
http://echa.europa.eu/web/guest/candidate-list-table

This work is not at all as simple as we would think, therefore it is useful to develop a good database. I can recommend companies with experience in developing REACH databases.


According to Article 7(6) a registration or notification of a substance in articles is not required, if the substance has already been registered for that use (i.e. the process by which the substance is included in the articles). This refers to any registration of that use of the substance in the same supply chain or any other supply chain.


3. Communication requirement:



If any of the chemical substances in the given candidate list can be found in the article at a concentration exceeding 0.1 weight percentage (w/w), then the manufacturer /importer of the article must indicate in a statement for their supply chain in the next supply, and at the request of the consumers, that the article contains chemical substance included in the candidate list. The related information must be provided to the consumers free of charge, within 45 days of receiving the request.

Therefore the main objective is to exclude all chemical substances from the articles, which are found in the candidate list, in order to avoid having to comply with the additional requirements. I would like to raise your attention to the fact that the addition of further substances to the candidate list will depend on the results of the toxicological tests. It is expected that a new list will be issued every year.