Chapter 2 - REACH—Life In and Outside the EU: How REACH Will Affect the Supply Chain

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REACH is a European regulation on registration, evaluation, authorization, and restriction of chemicals (REACH), which was enforced on June 1, 2007. This chapter provides guidance on what typical requirements and responsibilities are under REACH, and what options companies have in addressing the REACH requirements and responsibilities, especially when dealing with the complexities of a supply chain. The main aims of REACH are to improve the protection of human health and the environment from the risks that can be posed by chemicals, the promotion of alternative test methods, the free circulation of substances in the internal market, and the enhancement of competitiveness and innovation. REACH is principally broken down into five stages: Material Safety Data Sheets (MSDSs), Preregistration, Registration, Authorization, and Restrictions. The first step in preparing for REACH is to assess products and define them as substances, preparations, or articles. Cosmetics generally fall under the definition of preparations; thus all ingredients require registration. Preregistration is free and only basic substance and company information needs to be submitted. Preregistration is required only for substances that could potentially be imported or manufactured in excess of 1 ton (per legal entity) in the following year. Registration is the largest, most important part of REACH. Complete substance identification (including compositional information of multiconstituent substances), testing data, and safety assessments must be submitted to the European Chemicals Agency (ECHA). The authorization and restriction requirements target known and suspected carcinogens, mutagens, and reproductive toxins as well as persistent bioaccumulative toxins and other chemicals of similar risk. Companies can use a two-phased approach to meet the requirements of REACH: phase 1 should address the identification of requirements, responsibilities, preregistration, and timelines, and phase 2 should focus on the execution of responsibilities including documentation, supply chain data gathering, and registration.