REACH Hub
December 11: How should Siefs prepare to handle the C&L inventory?
To comment on this column, please go to Chemical Watch Forum
-------------------------------------------------------------------------------------------------------------------------------------------- NEW DISCUSSION FORUM WITH ReachCentrum* To comment on this column, please go to Chemical Watch Forum --------------------------------------------------------------------------------------------------------------------------------------------------------------------- ARCHIVES OF PAST "DR REACH DEBATES" COLUMNS: Question: Will the identity of a registrant that has appointed a 'third-party representative' be made visible to others at the time of registration? Dr Reach answer (November 2008) Question: What are the requirements for communicating Candidate List substances in articles? Dr Reach answer (November 2008) Question: How are nanomaterials managed under REACH? Dr Reach answer (October 2008) Question: What are the 40 Directives and Regulations that REACH is said to replace? Dr Reach answer (October 2008) Question. Does a substance meet the definition of a polymer under REACH? Dr Reach answer (September 2008) Question: "How much will REACH Registration cost?" Question from a Brazilian producer of speciality chemicals. Dr Reach answer (July/August 2008) Question: "How can a company register monomers bound in an imported polymer?" Question from a medium-sized Turkish company. Dr Reach answer (July/August 2008) 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 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 Question: "How can one identify chemically modified naturally occurring substances?" The questioner represents a Chinese REACH centre. Dr Reach answer (April 2008): Click here 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 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 here 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 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 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 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 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 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.November 11: Change management’s role is key going forward
September 11: Many questions tackled, many more to go
June 11: Updates, compliance checks and more updates
April 11: Dr Reach: Preparing for REACH audits and inspections
March 11: Dr Reach: Be prepared to update registration dossiers
December 10: Dr Reach: The eleventh hour: why registration went to the wire
November 10: Dr Reach: How many experts does it take to make a registration dossier?
October 10: Dr Reach: Please don’t ask me for a registration number
September 10: Dr Reach’s Top Ten tips for registration in 2010
Jul-Aug 10: Dr Reach: Should I submit a CSR jointly or separately for registration?
June 10: Dr Reach: Fixed goalposts are vital to REACH implementation
May 10: Dr Reach: REACH and CLP deadlines – getting it right
April 10: Dr Reach: Thinking ahead to 2013 and “data poor” substances
March 10: Dr Reach: Intermediates and authorisation – why cause such panic?
February 10: Dr Reach: Harmonisation on substance restrictions under REACH?
December 09/January 10: Traceability and transparency key to good REACH decisions
November 09: Tougher product safety laws demand holistic thinking
October 09: How much to budget for REACH registration in 2010?
September 09: Would Paracelsus have liked exposure-based waiving?
July/Aug 09: How REACH is raising the bar for risk management
June 09: Let’s have a public airing of CLP questions to authorities
May 09: Who are you? - by a REACH consultant
Apr 09: Dr Reach - Claiming due diligence for substances in articles
Mar 09: Dr Reach - Common sense needed for reaction mass registration
Feb 09: Dr Reach - Focus on data sharing aims to streamline SIEF formation
Jan 09: Dr Reach - Does double pre-registration make sense?
------------------------------------------------------------------------------------------------------------------------------------------------------ Previous Dr Reach Q&A columns:
Do third party representatives ensure confidentiality?
Candidate List substances in articles
How are nanomaterials to be registered under REACH?
What legislation does REACH replace?
When is a substance a polymer?
How much does registration cost?
Monomers in an imported polymer
Substance, polymer or preparation?
Substances and preparations
Natural substances
Candidate list
Paint producers
Only representative
Process gases
Information for pre-registration
Biocides and REACH
Intentional release
REACH registration and imports
The REACH Hub
To comment on any of these posts, please go to Chemical Watch Forum where you may also comment anonymously.
* The team at ReachCentrum were appointed to write for Chemical Watch's monthly REACH discussion column in November 2011.
ReachCentrum was created in June 2006 by Cefic (the European Chemical Industry Council) to help companies all through the value chain to prepare and implement REACH.
The organisation helps chemical manufacturers and importers, as well as downstream users and distributors to comply with all three aspects of the REACH legislation: dossier preparation for registration and support through the phases of evaluation and authorisation.
It provides services and tools for consortia, lead registrant and Sief leadership teams, consultancy and workshops. These are designed for European and non-European companies working on their own or in close collaboration with other companies. Its specialists have years of experience dealing with different aspects of chemical industry activity.
Legal Disclaimer: The information contained in these communications 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 these communications.