REACH

Registration, Evaluation, Authorisation and Restriction of Chemicals

REACH status of major products handled by JMB (as at end April 2014):

Please contact us for information on products not mentioned

Introduction

After a number of years of discussion, the EU's REACH scheme for chemicals was finally agreed in December 2006 as EU Regulation 1907/2006. As a Regulation, rather than a Directive, REACH came into force in the whole of the EU on the same day - 1st June 2007.

REACH is the most complex legislation ever to affect chemicals and it will have major impacts on all chemical users. Because of this complexity, REACH will be implemented in stages over a total of eleven years.

The scope of REACH is also considerably wider than any previous legislation and, for example, it will not only affect JMB as a chemical manufacturer and importer, but will also affect our customers, their customers, their customers etc, stopping only at the consumer level.

REACH will even affect companies producing "articles", where the presence of chemicals may offer a health and/or environmental hazard. As an example, a ball-point pen would not normally be judged as being a "chemical", but if the chemicals in the liquid ink offer a hazard, then the pens may also be covered by REACH requirements - it having been agreed that they should be treated as being containers for the ink within.

It is important to realise that REACH covers chemicals singly - not mixtures. If a particular product is a "preparation" (ie a mixture) then REACH will require the registration of the components present in the preparation. When, and in what detail, the different components have to be registered depends mainly on the quantities handled per annum by the manufacturer / importer into the EU.

Please also note that many products which you may not normally think of as being "chemicals" will come under REACH eg carbon black or titanium dioxide. The only safe course is to assume that all the materials you handle are subject to REACH, unless you can prove that they fall outside its range.

REACH Implementation

A small number of chemicals are excluded from REACH registration obligations because their intrinsic properties mean that they offer very little risk to human health or to the environment. These are listed in the updated Annexes IV and V (please see below for a link).

The first major stage of REACH took place in the second half of 2008 - 'pre-registration'. This process allowed all such pre-existing chemicals to be granted a delay before full registration has to take place - this delay varying with the hazard classification of the chemical and the annual volume handled by the manufacturer / importer.

For importers / manufacturers handling more than 1 tonne per annum of any substance for the first time, there still exists the possibility of making a "late pre-registration" - within certain restrictions (see the legislation for full details). This possibility is not available if a manufacturer / importer has simply missed the pre-registration deadline.

If a late pre-registration is not possible, after 1st January 2009 all chemicals which have not been pre-registered must go through full REACH registration before they may be manufactured / imported into the EU in quantities above 1 tonne per annum..

JMB REACH Implementation

JMB has pre-registered all chemicals it manufactures or imports into the EU, unless the chemical is either a) excluded from REACH (annexes IV and V) or b) the quantity handled is below the REACH trigger level of 1 tonne per annum.

We have also pre-registered all relevant process intermediates and ensured that suppliers of critical raw materials have pre-registered the chemicals we buy from them.

We have contacted the manufacturers of the materials we merchant for information on their plans for REACH compliance. We have confirmed that all necessary pre-registrations have been carried out and, in several cases, these substances have now been registered - please see further information below.

An important part of REACH is the flow of information from manufacturers down the supply chain to customers and the reverse flow of information up the chain from customers covering information on usage etc up the chain to manufacturers / importers.

If any customer thinks it possible that their use of any material we supply is "unusual" and may not be covered by a general registration, we would strongly suggest that they contact us so that we can ensure that the company registering the product is made aware of this specialised use.

The registrant may or may not choose to include the specialised use in its registration : if it declines to do so, the end-user can choose to do so itself.

The EU operates a scheme to control the use of substances which it considers to be of special concern. Such substances may be added to the 'candidate list' and are subject to specific requirements : the current 'candidate list' may be found here. Substances may be selected from the 'candidate list' to be added to Annex XIV of REACH : these are then subject to the authorisation process. Substances included in Annex XIV are assigned a 'sunset date' and may not be used after this unless their use is specifically authorised.

We keep a regular check of the so-called 'registry of intentions' - where announcements are made recording possible action on specific substances - and we advise affected customers as soon as substances in any of the products we sell appear.

What do downstream users of chemicals need to do?
Where do we find further unformation on REACH ?

Any customer who hasn't yet checked how REACH will affect them should do so as a matter of urgency, as it is possible that they may discover that a chemical critical to their operations may no longer be available if the manufacturer / importer into the EU decides not to put it through REACH. The actual legislation, official guidance for downstream users and much other help is available (please see details below).

Many of our downstream users belong to trade associations for the plastics, coatings, paints and ink industries. Many such bodies have established working groups to coordinate their members' response to the many new requirements established by REACH and to advise them on how particular sections apply to their products.

The UK Chemical Industries Association has set up a subsidiary called "REACHReady" to help its members comply with REACH - please find further details below.

To help our customers keep up-to-date with the developing REACH situation and to raise specific points of interest, we have produced a number of short REACH newsletters. If you haven't yet contacted us about REACH, please do so as soon as possible and provide full contact details of the person dealing with REACH. Please also advise if you would like copies of our REACH newsletters.

Recommended downloads

The shortened and corrected version of the REACH Regulation can be downloaded using this link (278 pages).

Please note that annexes IV & V of this document - which list substances excluded from REACH registration - have now been replaced by updated versions.

We strongly suggest that all our customers download the official guidance for downstream users of they have not already done so. This document was updated at the end of 2013 and the new edition (132 pages) can be found here.

Useful links

European Chemical Agency (Helsinki, Finland)

All official guidance documents on REACH are now on the ECHA Internet site and can be located here.

European Chemical Bureau (Ispra, Italy)

Although this site no longer includes any REACH guidance, it still has useful information available.

For example, the ECB site has an online version of the EINECS chemical inventory, searchable by chemical name, CAS Registry Number and EINECS number.

It also hosts the online official EU classification and labelling database, as opposed to the classification inventory on the ECHA site, which records mainly data submitted by companies and which has no legal standing.

REACHReady

This has been set up by the UK Chemical Industries Association to help its members comply with the complex requirements of REACH. As a member of CIA, JMB has free 'gold-level' membership : FREE 'silver-level' membership is open to all. We have found this organisation well-informed, helpful and efficient in dealing with questions.

UK Health & Safety Executive

The HSE is the Competant Authority in the UK for REACH. It publishes free REACH e-bulletins from to time: as these are free, it would seem sensible for all our customers to sign up! This can be done using the link here.

HSE has set up a help desk for REACH-related queries : the contact email address is This email address is being protected from spambots. You need JavaScript enabled to view it.

JMB REACH contact

The person dealing with REACH matters at James M. Brown Limited is Phil Rowley. Please find contact details below:

telephone: + 44 (0)1782 744171
fax: + 44 (0)1782 744473
e-mail for REACH matters: This email address is being protected from spambots. You need JavaScript enabled to view it.

The information we have posted on REACH will be reviewed from time to time and, where necessary, further information or extra pages will be added.