REACH Regulation (EC 1907/2006)

REACH was introduced for worthy reasons, to collect and disseminate hazard data on new and existing chemicals in a harmonised way in order to enhance health and environmental protection.  It shifted the main responsibility for compliance firmly onto industry and introduced mandatory co-operation between otherwise competing chemical companies within single-substance SIEF groups.  Unfortunately its implementation has highlighted some problematic areas (including complex supply chains, polymers and certain petrochemical UVCB categories) and the new regulatory regime of ECHA has proved less available for constructive pre-registration discussion of difficult cases than earlier European regulatory agencies.

However the first REACH registration deadline for phase-in substances is now behind us: here at BCS we have successfully created and submitted registration dossiers:

• as Lead Registrant
• as co-registrant, after working within industry consortia to develop agreed joint registration dossiers
• as co-registrant, having purchased Letters of Access from Lead Registrants
• as stand-alone registrant of a new (non phase-in) substance
• as updates to REACH registrations granted as we previously notified into ELINCS.

We have also advised major consortia on registration strategies and assisted with dossier preparation in many cases where we were not acting as registrant (appointed Only Representative of a non-EU client), as well as assisting with PPORD applications and prior registration enquiries.

Current REACH-related projects include programmes for new substance testing and registration, preparation for expected authorisation requirements and registration updates triggered by increased tonnage.

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