Should you worry about REACH?

Reach Basics

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Many of our subscribers ask us if they will be affected by REACH and the short answer is normally "Yes".
 

But how worried should you be about the amount of work you must do? We've developed this tool to help you decide.

  The happier the face, the happier you'll be too. Hover your mouse over the people to get more detailed information.
Your Situation

REACH

Registration Needed?

Chemical Safety Report / Risk Management Communication Needed?

Article Notification & Communication Required?

Safety Data Sheet / GHS

Changes Required?

I manufacture / import less than one tonne of a substance each year

No. There is no need to register
Yes, but only if a substance of very high concern
Not applicable
Yes

I manufacture / import more than one tonne of a substance each year
Yes
Yes. CSR required for supply over 10 t per annum, and for substances of high concern under 10 t.
Not applicable
Yes

I manufacture substances (>one tonne per year) in the EU and export them outside the EU
Yes
Yes, but only for EU exposure
Not applicable
Yes

I buy in substances from EU suppliers who have REACH registered and make mixtures
No, not if your supplier has already registered the substance for your use
Yes. Check you and your customers use is covered by the CSR Exposure Scenarios given to you by your supplier
Not applicable
Yes

I buy in substances that are REACH registered and make articles
No. Not if your supplier has already registered the substance for your use
No. Not if your supplier has already registered the substance for your use
Yes, but only if hazardous substances are released or contains a substance subject to authorisation
No. An SDS is not required for finished goods

I use chemicals and buy from EU sources

 

No. Not if your supplier has already registered the substance for your use
No. Not if your supplier has already registered the substance for your use
Yes, if hazardous substances are released from what you make
Yes
Your Situation

REACH

Registration Needed?

Chemical Safety Report / Risk Management Communication Needed?

Article Notification & Communication Required?

Safety Data Sheet / GHS

Changes Required?

I import cosmetic ingredients to make finished cosmetic products
Yes. The cosmetic ingredient needs to be registered
Yes, though the CSR need not include consideration of the risks to human health
No
No

I import natural oils and sell to the food industry as additives
No. Registration not required for this use
No
Not applicable
Yes

I import cosmetics in their finished form

 

Yes. The cosmetic ingredient needs to be registered if considered to be a preparation
Yes, for all components subject to registration, though the CSR need not include risks to human health
No
No

I make food additives and export outside the EU
No, registration not required for this use
No
Not applicable
Yes

I import polymers

 
Yes, the monomers and chemicals making up >2% and 1 tonne or more per year have to be registered.
Limited to the monomer and chemical components
Yes. Only if hazardous chemicals are released
Yes, but limited to polymer

I make surfactants that go into pesticide formulations and other uses. *

Yes, but not for pesticide use covered by Directive 91/414/EC
Yes, but not for pesticide use covered by Directive 91/414/EC
Not applicable
Yes, until supplied as a finished pesticide
Your Situation

REACH

Registration Needed?

Chemical Safety Report / Risk Management Communication Needed?

Article Notification & Communication Required?

Safety Data Sheet / GHS

Changes Required?

I make pesticide active ingredients for export

 

Yes, if not registered as pesticide in EU
Yes, but only for EU exposure
Not applicable
Yes

I make a series of intermediates as part of the chemical process
Yes, but limited requirements depending on type of intermediate
No, CSR not required
Not applicable
Yes

I buy or sell intermediates as part of manufacturing
No. Not if your supplier has already registered the intermediate
No, CSR not required. But need to confirm use under strictly controlled conditions
Not applicable
Yes

I make finished goods in the EU and sell them into the EU
No. As long as the substance has already been registered for that use
No.
Yes, if contains >0.1% w/w of a substance of very high concern and on the candidate list duty to communicate
Not applicable

I make finished goods outside the EU and export them to the EU *

Yes. Any unregistered substances that are intended to be released have to be registered for your particular use
No
Yes, if contains >0.1% w/w of a substance of very high concern and on the candidate list duty to notify and communicate
Not applicable

I make chemicals that go into medicinal or veterinary

products
No, registration not required for this use
No
Not applicable
Yes

I buy in waste and scrap, recover, recycle or reprocess it and sell it on
Yes, if the substance you sell on is not the same as the one that has already been registered by someone else
Yes, if registration is required
No
Yes
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