It's time to get ready for REACH

How businesses manufacture, import or use substances is coming into the spotlight under the registration, evaluation, authorisation and restriction of chemicals programme (REACH).

On June 1, the first milestone under REACH was marked by the start of the pre-registration period - an important new stage in European chemicals management.

Getting onside with the new rules under REACH will involve a fact-finding mission about your business – including the substances you use, how exactly you use them, and who you rely on to supply them.

If you think that REACH will only affect big businesses who deal in large quantities of chemical products - then think again. If you use chemicals to keep your machinery operating and your premises clean, if you import products like cars or batteries, or if you receive substances containing chemicals through a supplier and use them in an unusual way – then it's likely you'll need to take some action under REACH.

If you own or operate a business, it makes good business sense to get on-board with REACH as soon as possible. The best thing to do is find out as much as you can about these new rules and how they might affect your business as soon as you can. There are resources available to help you do this, such as the REACH Competent Authority website and helpdesk.

Who is affected?

If you make chemicals for yourself or supply them to other people, it's likely you will be affected by REACH. This applies to any chemical that is manufactured in quantities of one tonne a year or more – although there are a few exceptions.

If you directly import chemicals into Europe in quantities of more than one tonne a year, you will also be affected by REACH. This includes chemicals imported in mixtures (e.g. paints, cleaning agents) and articles (like cars or batteries).

Businesses using substances down the supply chain also need to be aware of REACH. Downstream users may include businesses using substances to keep their machinery operating and their premises clean; formulators of preparations (like paints, glues, detergents, plastics or rubbers); users of chemicals (like oils, lubricants, antifoams) in industrial processes; professional users (like car repair shops and cleaners) or producers of articles (like electronic components, computers, toys or cars).

And finally, if you're a smaller business relying on a supplier for products, it's a good idea to get a better idea of which substances you rely on, and where they are imported from. This is to ensure that you will be able to keep using these substances in the future.

What do I need to do right now?

Under REACH, chemicals manufactured or imported into the EU in quantities of over one tonne need to be registered with the European Chemicals Agency (ECHA) in Helsinki. This process kicked off with the pre-registration period from June 1.

If you manufacture or import chemicals at over a tonne or more per year, in order to pre-register you'll need to be aware of the makeup of these products. This includes substances you use and all the ingredients of any preparations (that is, mixtures). If you produce finished products such as cars, batteries and telephones, you need to find out if there are any substances in these products that exceed a total quantity of one tonne per year.

If your business purchases substances from a supplier, you will need to look at what you use and how you use it. If you use a chemical in an unusual way, you might need to let your supplier know, because they will need this information for their registration. Generally, if you are using chemicals or mixtures of chemicals (such as paint, lubricants, cleaning agents) in the way that is expected, then REACH probably won't mean significant changes for you. However, if you use unusual chemicals, you might choose to contact your supplier to check their plans for supplying this chemical in the future.

What is the pre-registration period?

Pre-registration runs between 1 June and 1 December 2008, and involves providing ECHA free of charge with some basic information on the substances you are manufacturing or importing, the quantities involved, and the contact details of your company's REACH person (and the name of a third party if you appoint someone).

In order to be eligible to pre-register, you'll need to meet some criteria. Generally, your chemical needs to be on the "existing substances" list of the European Inventory of Existing Chemical Substances (EINECS), which means it must also have been placed on the European market before 1981. Specific guidance on this can be found at http://www.hse.gov.uk/reach/.

What are the benefits of pre-registering?

If you take part in the pre-registration process, you’ll be able to take advantage of a longer time to fully register than would otherwise be available, by qualifying for the staggered registration deadlines after 1 December. The timing of these deadlines depends on the hazard classification and tonnage of the substance being registered.

If you don't pre-register, you can't take advantage of these staggered deadlines and will need to register your substance fully immediately after 1 December 2008 and stop its manufacture or import while you do this.

Once pre-registration has taken place, the European Chemicals Agency will identify who has pre-registered the same substance and put them in contact with each other. The potential registrants can then come together and form a 'Substance Information Exchange Forum’ (SIEF) where they can negotiate sharing their available data and the costs of generating any new data for a joint substance registration dossier. Registration costs themselves are also reduced through this collaborative process.

Phil Woolas MP is Minister of State for the Environment. He is responsible for climate change, energy and sustainable development.