The REACH Regulation (EC 1907/2006) governs the Registration, Evaluation, Authorisation and Restriction of Chemicals. It applies to all chemical substances, not just those used in industrial processes. This checklist helps manufacturers, importers, and downstream users navigate their REACH obligations.
Phase 1: Inventory and Role Identification
- Identify Your Role: Determine if you are a manufacturer, importer, downstream user, or distributor under REACH. Your obligations depend entirely on your role.
- Create a Substance Inventory: List all chemical substances you manufacture or import, whether on their own, in mixtures, or intended to be released from articles.
- Calculate Tonnage: Calculate the annual volume (in tonnes per year) for each substance. Registration obligations trigger at 1 tonne per year.
Phase 2: Registration (Manufacturers and Importers)
The core principle of REACH is "No data, no market."
- Check for Exemptions: Verify if your substances are exempt from registration (e.g., polymers, substances covered by other specific legislation, or Annex IV/V substances).
- Gather Data: Collect all available data on the physicochemical, toxicological, and ecotoxicological properties of the substance.
- Join a SIEF/Consortium: For phase-in substances, join the Substance Information Exchange Forum (SIEF) to share data and costs with other registrants.
- Prepare the Registration Dossier: Use the IUCLID software to prepare the technical dossier. If volume exceeds 10 tonnes/year, a Chemical Safety Report (CSR) is also required.
- Submit to ECHA: Submit the dossier to the European Chemicals Agency (ECHA) via the REACH-IT portal and pay the registration fee.
Phase 3: Supply Chain Communication
- Provide Safety Data Sheets (SDS): Supply an updated SDS to downstream users for hazardous substances and mixtures.
- Communicate SVHCs in Articles: If you supply an article containing a Substance of Very High Concern (SVHC) above 0.1% weight by weight, you must provide sufficient information to allow safe use (Article 33).
- SCIP Database Notification: Notify ECHA's SCIP database if your articles contain SVHCs above the 0.1% threshold (required under the Waste Framework Directive).
Phase 4: Authorisation and Restriction
- Check the Candidate List: Regularly monitor the SVHC Candidate List to see if your substances are added.
- Check the Authorisation List (Annex XIV): If a substance is moved to Annex XIV, it cannot be used after the "sunset date" unless an authorisation is granted by the European Commission.
- Check the Restriction List (Annex XVII): Ensure your substances or articles comply with any specific conditions or total bans listed in Annex XVII.