Chemicals 2017-05-14T20:15:05+00:00

REACH and CLP

For scientific research, the regulatory requirements are low. But even for laboratory work, knowledge of physico-chemical properties (e.g. combustibility) is important. Essential information regarding toxicity should also be known.

If your company produces or imports more than one tonne of a substance per year, a registration under REACH is required. If another company has already registered the substance, you can refer to that information but must contribute financially. If you, however, are the first registrant, the time and expense will not be negligible. ⇒ Registration

For substances of very high concern, special communication obligations arise. Their further use may even require an authorisation by the European Commission. ⇒ Authorisation

Moreover, it is important to note restriction provisions; some substances are banned for certain uses or limited in their concentration.

The European regulations REACH and CLP are complex and involve various exceptions and deadlines. Many of the European Chemicals Agency’s guidelines offer help in understanding the requirements. However, the correct interpretation of the regulations, i.e. whether actions are required and what these are, can be a challenge. The European Court of Justice has the final say in how laws are to be interpreted and what needs to be done. ⇒ Concern analysis

What happens if someone ‘forgets’ to implement the regulations? The German Chemicals Act (§27b) can enforce strict penalties of up to five years’ imprisonment for wilful misconduct. But don’t worry: the prisons are not full of individuals who have violated REACH. However, how your customers will react to receiving non-compliant products and how this will affect your business is another matter.