Dr Reach
Read readers' questions and the answers by Dr Reach - and add your own questions
Substance, polymer or preparation?
Question: "A company imports a product that contains a polymer and other additives. Is this a substance, preparation or polymer and what must be registered?" The questioner is a Hungarian trade association.
Dr Reach answer (June 2008): Click here
Substances and preparations
Question: "Does a company purchasing 0.5 tonnes of substance A in preparation X and 0.5 tonnes of substance A in preparation Y need to register substance A?" The questioner is a Japanese consulting company.
Dr Reach answer (June 2008): Click here
Natural substances
Question: "How can one identify chemically modified naturally occurring substances?" The questioner represents a Chinese REACH centre.
Dr Reach answer (April 2008): Click here
Candidate list
Question: "How many substances will be included in the 'candidate list' and when?" The questioner is a regulatory consultancy in the USA.
Dr Reach answer (April 2008): Click here
Paint producers
Question: "Do paint producers have to register substances?" The questioner is a small EU paint producer based in Portugal..
Dr Reach answer (March 2008): Click hereOnly representative
Question: "Can a company change the EU company that it wants to act as the Only Representative?" The questioner is a Chinese trade association.
Dr Reach answer (March 2008): Click here
Process gases
Question: "How can one interpret 'process gases and components thereof' as it appears in point 7 of the REACH Regulation Annex V?" The questioner represents a large chemical producer in Poland.
Dr Reach answer (January 2008): Click here
Information for pre-registration
Question: "What information is required for pre-registration of substances under REACH?" The questioner represents a multinational speciality chemicals firm based in Germany.
Dr Reach answer (December 2007): Click here
Biocides and REACH
Question: "Do biocides need to be registered under REACH?" The questioner is a global speciality chemicals manufacturer based in the USA that also exports to the EU.
Dr Reach answer (December 2007): Click here
Intentional release
Question: "Is a scented candle considered an article with a substance which is intentionally released under normal or reasonably foreseeable conditions?" The questioner represents an Italian regulatory and scientific consultancy.
Dr Reach answer (November 2007): Click here
REACH registration and imports
Question: "A non-EU company supplies my EU-based companies with products. Who is then responsible for any REACH-relevant obligations for the registration of the substances in those products?" The questioner represents an SME metals trader based in Italy.
Put your question to Dr Reach
Send your questions to steffen@chemicalwatch.com
We will not disclose your identity (unless of course you request that your name be included).
Dr Steffen Erler is Director of REACH Services at Smithers Rapra Technology. Over the past few years, he has been closely involved in the formulation of REACH and the REACH Implementation Projects (RIPs), including as a consultant for the UK Chemical Industries Association and REACHReady. As a chemist with experience in toxicology, Steffen gained a practical knowledge of chemicals policy through work with the OECD and European Commission.
He was dubbed “Dr Reach” by colleagues upon completion in 2007 of a PhD examining differences in chemical regulation across the France , Germany, Sweden and the UK. A key element of his research involved proposing risk-based approaches to implementing the hazard-based REACH Regulation. His thesis concluded that decision-making under REACH will often depend on Member State regulators and that this aspect of the Regulation, together with enforcement, remains largely unexplored.
Legal Disclaimer: The information contained in this communication follows a technical interpretation of REACH to serve as a thought-starter for discussions; it does not constitute legal or any other form of advice. Note that technical aspects are subject to review and references should be checked for updates. The legal text of the REACH Regulation must serve as the basis for REACH compliance and it may be advisable to seek legal and/or other expert advice on any given issue. The author and Chemical Watch accept no liability whatsoever with regard to the use of information contained in this communication.