When you look at a product, you most probably think about its quality, cost, design, and performance. But there is an important question that manufacturers cannot ignore: What chemicals are inside the product? A product that looks simple from the outside contains several chemicals that can affect humans and the environment. That’s where EU REACH compliance comes in. REACH is a union primarily concerned with chemical manufacturers. But if you are new to this term, worry not! In this guide, I will discuss what REACH is, who must comply with it, and more. So let’s get started.
What Is the EU REACH?
REACH stands for Registration, Evaluation, Authorization, and Restriction of Chemicals. It is a European Union regulation that controls how chemicals are made, used, and supplied in the EU market. It was established to reduce the risks created by harmful chemicals to people and the environment.
In simple words, REACH demands that businesses know which chemicals they use and manage them responsibly. However, one important thing is that REACH is not confined to companies that produce chemicals. It also affects manufacturers that use chemicals to make other products. For example, a company making plastic parts uses chemical additives. At the same time, a textile company might use dyes or finishing chemicals.
Now, if these substances fall under REACH requirements, the company must check and manage them properly. They have to comply with REACH before supplying their products to the EU market. So, REACH places more responsibility on businesses. It doesn’t wait for the moment when chemicals will cause harm. Instead, it urges companies to collect information about the substances they use and to know their potential risks in advance.
Why Is Compliance with REACH Important?
There are many reasons that justify why REACH is important. First of all, chemicals are present in almost every modern product we use daily, but not all are safe. Some of them create serious problems for human health and the environment if they are used in the wrong way or in high amounts. However, REACH helps companies understand these risks and use chemicals more safely.
It makes manufacturers pay attention to what is actually inside their products. Companies have to identify which chemicals they use, how much they use, and whether those chemicals pose any known risks. If a substance is considered dangerous, the company needs to limit its use. Otherwise, the company must provide safety information or find a safer alternative.
These are the requirements of REACH. All these make the environment safe from dangerous chemicals. Lastly, REACH is important from a business perspective. Suppose a company wants to sell its products in the EU; it must comply with REACH. If it does not, its products may face delays and restrictions. Compliance with REACH also helps businesses win customer trust.
Who Must Comply with REACH?
REACH affects many businesses, not just companies that make chemicals. The exact responsibility depends on what a company does with a substance. Manufacturers, importers, and even companies outside the EU must comply with REACH.
Manufacturer
Manufacturers are companies that make chemical substances in the EU. If that manufacturer produces a product in the EU, it first needs to check whether REACH registration is required. It mainly depends on the type and yearly amount of the substance. If a restriction is required, they have to collect information about the chemical and show how it can be used safely. The manufacturer also needs to understand the rules that apply to that substance.
Importers/Suppliers
Importers bring chemicals or other goods from outside the EU into the European market. For them, the first step is knowing exactly what they are bringing in. If their product contains substances, some of which have REACH requirements. The importer will need to ensure that the required registration and safety information is in place. This information will help them avoid compliance issues later.
Downstream Users
Not every company makes chemicals. Some businesses buy them and use them to make something else. These companies are known as downstream users. A factory, for example, purchases a kleefspray voor stof and uses it to assemble products. That’s a downstream user. This user still needs to use that chemical safely. At the same time, they have to follow the instructions and conditions given by its supplier.
Non-EU Exporters
A company does not have to be located in Europe to be compliant with REACH. A manufacturer in another country sells plastic parts, textiles, electronics, or other goods to an EU customer. In that case, the European buyer will ask for information showing that the product meets the relevant REACH requirements.
The Four Main Parts of EU REACH
REACH sounds complicated because it uses four different terms. However, the basic idea is quite simple. These four parts help control chemicals from the time they are made or imported until they are used. Here are the four parts of REACH you must know.
1- Registration
The first major part of REACH is restriction. In this part, the manufacturer gives the authorities information about the chemical they are using. Companies that make or import certain chemicals in the EU must register them with ECHA. They have to provide details about the chemical, such as what it is, how much is made or imported, and whether it can be harmful.
2- Evaluation
Evaluation means checking the information that companies provide. Authorities look at the data to see if it is complete and if the chemical could cause harm. If they find a problem or need more information, they ask the company for additional data. In simple terms, evaluation is about understanding the possible risks of using a chemical.
3- Authorization
Authorization is all about special permission to use certain harmful chemicals. Some chemicals cause serious problems for people or the environment. When such a chemical is placed under the authorization system, a company needs permission to continue using it for a specific purpose. If the chemical is very harmful, the authority might require the company to use a replacement.
4- Restriction
Now, it comes to restrictions, where limits are sometimes placed on a chemical, or it is entirely stopped from being used. For example, REACH might sometimes say that a chemical cannot be used above a certain amount. In some cases, a particular chemical creates too much risk, and its use may be completely banned.
How Manufacturers Can Achieve REACH Compliance: Step-by-Step Guide
Now you have a basic idea of REACH, its parts, and its importance. Right? Now it’s time to look at how companies can comply with REACH. Remember, this is not a straightforward process. Instead, manufacturers must follow the steps listed here to achieve compliance.
Step 1: Identify Your Chemicals
The first step is to find out what chemicals are used in your products. Make a list of the substances used in raw materials. Not only this, but also identify coatings, adhesives, plastics, dyes, and other parts of the manufacturing process. Don’t look only at the final product. Even small chemical additives used during production matter. If you are not a manufacturer, ask your suppliers for clear information about all materials.
Step 2: Check the REACH Applicability
Once you know which chemicals are present, check which REACH rules apply. Remember niet every chemical has the same REACH requirement. Some chemicals might need only a restriction; some might have restrictions. So, in this step, you have to know which REACH rules apply to the chemicals in your product. Suppose you manufacture a plastic product. You find that the plastic contains several additives. Now you check each substance to see whether REACH covers it, restricts it, or treats it differently.
Step 3: Review Supply Chains
After checking which REACH rules apply, the next step is to talk to your suppliers and check the materials they provide. Basically, a manufacturer does not always make every material itself. So it might not know exactly which chemicals are inside each material. For example, an adhesive manufacturer buys additives from another company.
In this case, they have to ask for all the information about that additive. It is a good idea to ask suppliers for documents such as Safety Data Sheets (SDS) and REACH declarations. Also, do not depend on old information forever. Suppliers change their materials, ingredients, or manufacturing processes. So regularly updated information is crucial for REACH compliance.
Step 4: Check from SVHC Lists
Now you have a supply chain. The next part is to find out whether any of the substances in your products are on the SVHC. SVHC stands for (Substances of Very High Concern), which is the Candidate List. These are chemicals that the EU considers concerning because they cause serious harm to people or the environment.
The list is updated over time, so you should not think that an old check will always be enough. So compare the chemicals in your materials with the current SVHC Candidate List. Check whether your product contains any chemicals of concern to the EU. If you find one, do not ignore it. Now check what REACH requires for such chemicals.
Step 5: Prepare Your Documentation
Once you know which chemicals are in your product, it comes down to keeping the right documents as proof. These records show what materials you use, where they come from, and whether they meet the required REACH conditions. These are the documents you have to keep.
- Veiligheidsinformatiebladen (SDS)
- supplier declarations
- REACH statements
- test reports
- information about the chemicals used in your products
If your supplier tells you that a material does not contain certain restricted substances, keep that information as well. Keep these documents organized and up to date. If a customer asks whether your product complies with REACH, you can quickly provide the required information. If a supplier changes a material, you should also update your records.
What are the Consequences of Non-Compliance with EU REACH?
Not following REACH creates serious problems for a manufacturer. First of all, if a company sells a product in the EU without complying with the rules, the product will be prevented from being placed on the market. In some cases, authorities ask the company to remove the product or correct the problem. This can affect the company’s reputation in customers’ eyes.
Secondly, non-compliance with EU REACH also causes financial costs. Such companies can face penalties under the national enforcement rules of the EU country where the violation occurs. They may also have to spend extra money to retest products, change materials, and update documentation. Sometimes authorities also require the company to remove the product. All this removed product might go to waste, which causes financial losses.
Conclusie
EU REACH compliance might look difficult when you first hear about it. But the main idea behind this regulation is actually simple. It is a European organization that asks manufacturers to know what chemicals are in their products. It asks them to understand the rules that apply to them and to use those chemicals safely and responsibly.
So basically, REACH is mainly about reducing the risks posed by harmful chemicals to people and the environment. If you are a manufacturer, compliance with REACH is very crucial. However, you have to do this stepwise, as I have discussed in this guide. Remember, REACH is not just a set of rules to follow. Instead, it helps manufacturers make safe products and build trust among customers.