REACH - An Enforcement Update


In the months leading up to the REACH first registration date on 1 December 2010, the focus of the European Chemicals Agency (ECHA) was understandably on the 25,000 registration dossiers submitted. It is understood that it is still considering some of these, but it would still be safe to say that the ECHA's attention is now on matters of compliance.

What is important to remember in connection with REACH is that it has a continuing and evolving effect on your business. For example:

There are three further deadlines for manufacturers and importers:

- 1 June 2013 - registration for substances over 100 mts per year

- 1 June 2015 - the EU Regulation on Classification, Labelling and Packaging of Chemical Substances 1272/2008 will apply to mixtures

- 1 June 2018 - registration for substances over 1 mt per year.

While these dates may seem like a long time away, there is an aspect of REACH that could have a sudden and dramatic impact: an inspection from the local State competent authority.

Article 126 requires that each Member State has to lay down provisions for the enforcement of REACH. These provisions "must be effective, proportionate and dissuasive."

Article 121 states:

"Member States shall appoint the competent authority ... responsible for performing the tasks allotted to competent authorities under this Regulation and for cooperating with the Commission and the Agency in the implementation of this Regulation."

Please see full Alert below for further information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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