Another REACH deadline and how product stewards can prepare for it
The REACH deadline for registering all chemical imports into the EU at less than 1 metric tonne goes into effect in May 31, 2018.
“Many manufacturers of products and chemicals know this and are relying on their supply chain to support them,” says Andy Gbur, senior consultant at Tetra Tech. “However, this reliance poses a risk – not just with registrations, but also authorizations and restrictions – that they may not be aware of and unless exiting the EU market is their strategy, they need to act fast and take immediate precautions.
Part of the registration process is supplying large sums of information to ECHA about the substances physical properties, including toxicity, hazard assessments and end use. “It’s no small effort to do that. It can take anywhere from a year to two years to gather this data. Some suppliers may not see it as worth their effort to invest that much.”
If that’s the case, you could be in trouble if you rely on that supplier. “If your chemical is not registered, it will be illegal to place it on the EU market,” says Gbur. “You could find yourself in a jam at the deadline, where you’re not covered and you have to shut down the business line.”
To help product stewards prepare, Gbur will present REACH Regulation Compliance: The Risk with Depending Upon Supplier Coverage, a session at Stewardship 2017, where he’ll outline steps to take take to make sure you’re covered by the deadline. “Some suppliers have been telling people, it’ll be registered. It’ll be done,” says Gbur. “But it’s a business decision, and some have done a 180 degree turn and said they’re not going to cover it. The supply chain is going to bear the brunt of that.”
If suppliers say they’re going to do the registration, Gbur wants you to make sure. He’ll provide a set of questions to ask that will show whether the suppliers have made progress. If answers aren’t forthcoming, it’s time to put a backup plan in place. “If some of these substances are key components of your products, you should have contingencies in place in case your suppliers don’t deliver,” says Gbur. That could mean finding a different supplier, modifying your manufacturing process to remove the substance, or registering the chemical yourself.
“You should be having these discussions now,” says Gbur. “Come November at the conference, if somebody has an a-ha moment, I would say they’re in panic mode. But it’s still better late than never.”