Managing The Impact On Your Business

It's now two years since the REACH Regulation entered into force, and already many businesses are starting to see an impact on their products and supply lines.  Industry has expressed concern that some chemicals may be withdrawn from the market for a variety of reasons, both economic and regulatory; others may be restricted in their use through the Authorisation and Restriction processes of REACH. Downstream Users should already be thinking about the potential impact of REACH, assessing the risk to their own business and planning ways to manage those effects.  This continued action should help Downstream Users minimise the likelihood of REACH compromising production or product continuity.  Here are a few steps to help you on your way...

Identify business-critical substances

Look at what you buy. By compiling an inventory of which substances you buy and how you use them you can identify where your business is vulnerable: products you buy, products you sell, services you offer, processes you perform.

If you buy proprietary mixtures (formulations), knowing what substances you buy can be difficult. If you only know a mixture you buy is critical to your business, there may be a number of (unknown) business-critical substances.

Start collating information on "use"

Do you use chemicals to make other products, such as formulations or finished goods? Do you run processes on your site using chemicals? Do you re-pack and sell substances to customers, either on their own or in mixtures?

If you want your supply chain's registrant to include your uses in their registration dossier, they will need to know how you use the substance! It's not just your uses, either, but any processes or products your customers use the substance if they are also to be included in the registration.

Use a standardised, structured method to describe your uses – both to make life easier for the registrant and to ensure you don't share any confidential information. The Use Descriptor system described in Chapter R.12 of ECHA's guidance on the Chemical Safety Assessment should cover most Downstream Uses.

Communicate with your supply chain

Talk to your customers, to your suppliers and to your colleagues about REACH, its potential impact and your company's plans. Foster existing relationships and establish new ones if required.

Once you have the necessary information on uses to be included in your registrant's dossier, you'll need to let them know!

Use a structured, systematic approach in communicating with customers and suppliers to help your supply chain manage REACH effectively.

Communication in the supply chain is left for industry to manage – the regulators don't provide tools or deadlines for doing so. However, many industry groups and associations, such as Cefic, are preparing guidance and IT tools to help.

Be prepared for change

Product availability and pricing is likely to change significantly as a result of REACH. Being aware of what's happening in your supply chain can help you minimise the likelihood of REACH compromising your business.

There are a number of ways to manage the effects of REACH – REACHReady can help to identify the solution that is right for you.

Our Silver and Gold subscribers can download our REACH the basics information in pdf form from the Technical Downloads section of our website - for access either "Join for free", or "Login" if you're already a REACHReady subscriber.