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REACH and CLP regulations for chemical management: find out how the regulations affect your business

Written by Anna-Liisa Koskinen
16/09/2021

REACH and CLP regulations for chemical management: find out how the regulations affect your business

The safe use of chemicals and substances and mixtures containing them are regulated by several EU level and national regulations. In the jungle of regulations it can be challenging to understand what EU’s REACH 1 and CLP 2 regulations mean, and which obligations apply to your own business.

Production, EU imports, downstream use and distribution of chemicals are part of daily operations in many industries. Key EU chemical legislation is based on EU’s REACH regulation 1) and CLP regulation 2), which are implemented by the European Chemicals Agency (ECHA). The CLP regulation requires companies to identify and classify the hazardous properties of substances and mixtures, and to label and package these according to the hazard classification.

What is covered by REACH?

  • Substances (e.g. acetone, nickel, wood tar)
  • Mixtures (e.g. paint, detergent, concrete)
  • Articles (e.g. kettles, car tyres, batteries)

Topical in chemical regulation: circular economy, SCIP evaluation and notification of products, new substances, such as nano materials

Recently, circular economy has created a new kind of need for information regarding the chemical regulations. End-of-Waste substances (EoW) must also meet the REACH requirements. REACH contains exceptions for by-products which fulfil certain requirements and for previously registered substances.

There are also specific exemptions for scientific research and development (SR&D). It is often overlooked that even small amounts of substance used for scientific research and development purposes must be notified by the producer or importer to the ECHA classification and labelling inventory.

Articles containing certain hazardous substances (SVHC substances, Substances of Very High Concern) are reported to the SCIP database, which is managed by ECHA. SCIP-notification obligation became mandatory in Finland on July 19, 2021.

The REACH obligations of manufacturers and importers apply to nanomaterials (1–100 nm). The information requirements regarding environmental and health impacts and safety data sheets also cover nanomaterials.

A safety data sheet is prepared of substances and mixtures classified as hazardous regardless of the amount. The obligation to submit a safety data sheet does not depend on the quantities of substances but applies to batches of all sizes.

At AFRY, we help you with the obligations under REACH and CLP regulations

AFRY assists all stakeholders with the obligations and tasks under REACH and CLP legislation, from registrations required by REACH to submitting a national chemical notification. When evaluating the need for REACH services, we study which actions a certain substance, mixture or product requires before it can enter the market. We can make the inquiries, registrations and other notifications to the ECHA data systems on behalf of the client. Our team of REACH specialists consists of biologists, limnologists, chemists and engineers, which ensures that we also manage more demanding studies on the properties of the substances in question.

Our chemical management services:

  • Assessing the REACH service needs for companies
  • REACH inquiries for registration purposes
  • REACH registrations (e.g. acquisition of missing analysis and test data, chemical safety assessments, preparation of registration documents  (IUCLID) and registration (REACH-IT)​).
  • Safety data sheets
  • Hazard classification based on the CLP regulation

Notifications to authority registers:

  • SCIP register (ECHA)
    • Substances of Concern In articles as such or in complex objects (Products)
    • SCIP evaluation and notification (ECHA)
  • Kemidigi (Tukes)
    • Chemical lists and inventories
    • Gathering of information
    • Preparing and submitting of chemical notifications
  • Poison information centres (ECHA/Poison Information Centres)
    • Forming a Unique Formula Identifier (UFI)
    • Gathering of information
    • Notification to poison information centre portal
  • Notification to the classification and labelling inventory (ECHA, C&L notification)
    • Substances classified as hazardous

Contact

Anna-Liisa Koskinen

Senior Consultant Environmental Consulting, Environment Finland

Footnotes

  • 1. REACH regulation i.e. Regulation (EC) No 1907/2006 on registration, evaluation, authorisation and restriction of chemicals. REACH is an abbreviation of the words Registration, Evaluation, Authorisation and restriction of Chemicals.
  • 2. CLP regulation i.e. Regulation (EC) No 1272/2008 on Classification, labelling and packaging of substances and mixtures are key legislation. CLP is short for Classification, Labelling and Packaging.