The REACH regulation has significantly modified the manufacturing and importing strategies of chemicals in the European Union.
With the approach of the third and last deadline set for 31 May 2018 for all pre-registered phase-in substances, companies are proceeding with the implementation of their registration dossiers in order not to lose the deadline for registration of substances of interest.

Since 1 June 2018 REACH will end its 11-year "running-in" period and the "no data no market" principle of Article 5 of the regulation will be fully effective.
Basically a substance must be registered before it is manufactured or imported in quantities of 1 ton or more per year.

The "classic" registration provides for a joint registration for all companies that manufacture and import the same substance in the EU territory preceded by the purchase of a "Letter of Access" (LoA) whose amount can vary considerably, from a few thousand to a few hundred thousand euro for each substance and finalized with the payment of a registration fee proportional to the size of the company and the tonnage band of the registered substance.

The economic flow generated for REACH registrations will be absolutely relevant in the period January-May 2018 and will include all the data acquisition on the substances by the legitimate owners (data owners) or by the consortia established for this purpose.

Among the thousands of pages of guidelines issued by ECHA and the text of REACH I want to highlight only an excerpt from the recital (97) to the regulation:
The effective communication of information on chemical risks and how they can be managed is an essential part of the system established by this Regulation.

In the face of these enormous expenses to register substances, if the information on hazards and risks will not be communicated in the supply chain to the professional or industrial user, REACH will have failed its noble purpose and communication up and down the supply chain as requested by the regulation will not work.

The giant's head will be golden, but his feet will be made of clay!

If you are a downstream user according to REACH try to answer the following three questions:

1. Do you receive substance / mixture safety data sheets, including updates, from suppliers that follow an "active" supply method?
2. Do you receive the exposure scenarios for some or all of the hazardous substances indicated in section 3 of the safety data sheet?
3. When you receive an exposure scenario of a substance / mixture, is the document written in your language?

If you answered 3 times "NO" you have found that the giant's feet are made of clay!

For any request, please write to me at scibilia@flashpointsrl.com

Dr. Gabriele Scibilia