By now all companies doing business with and within EU should know about the REACH legislation and know if they are REACH compliant.
I have visited several companies the last 6 month, and to my surprise they have not heard about REACH. And that is despite that REACH was decided by EU back in 2006 and should be fully implemented in the involved companies in 2010, 2013 or 2018 depending of the volume of substances they are using in the company.
Now if the authorities fails in communicating the impact of the REACH legislation, could we then just say that it is the single company who has the responsibility of knowing all legislation’s which could be important for the company or does we as consultant who can offer a software solution like SAP REACH also have some responsibility of educating the companies in new legislation’s?
REACH – Registration, Evaluation and Authorization of Chemicals
The EU REACH regulation requires that substances that are placed on the market within the EU need to be registered with the European Chemical Agency (ECA). This regulation applies not only to chemical companies, but to any company that uses chemicals.
The REACH legislation contains a list of more than 30.000 substances and require that a company is able to classify their materials at substance level and in some cases is able to make a Substance Volume Control.
So the first step is to analyze if a company is using any of those substances, which are on the list from EU.
By now most companies have their 2010 substance registrations addressed, but the next phase-in tier registration deadline rapidly approaches.
The June 2013 deadline affects substances placed on the EU market at or above 100 tonnes/year; reducing the threshold by two orders of magnitude. This and the final threshold of just 1 tonne/year (due in 2018) drives an exponential increase in the number of substances impacted and therefore the numbers of products and companies subject to REACH compliance obligations.
Comprehensive enterprise system solutions are even more critical therefore to efficiently and effectively manage the work load to achieve, maintain, and prove compliance. REACH is a complex regulation and compliance actions extend heavily into the supply chain necessitating robust collaboration abilities efficiently managed only by leveraging IT tools and systems. Your right to operate depends on your ability to provide legally compliant reports and auditable results, as well as a comprehensive business process support.
To get detailed knowledge about REACH, do read the below EU guidelines:
Nearly all companies doing business with or with in EU is a subject for REACH
Depending of which role a company has, there is different obligations. The roles in the EU legislation are:
If you make chemicals, either to use yourself or to supply to other people (even if it is for export), then you will probably have some important responsibilities under REACH.
If you buy anything from outside the EU/EEA, you are likely to have some responsibilities under REACH. It may be individual chemicals, mixtures for onwards sale or finished products, like clothes, furniture or plastic goods.
- Downstream users:
Most companies use chemicals, sometimes even without realising it, therefore you need to check your obligations if you handle any chemicals in your industrial or professional activity. You might have some responsibilities under REACH.
- Companies established outside the EU:
If you are a company established outside the EU, you are not bound by the obligations of REACH, even if you export their products into the customs territory of the European Union. The responsibility for fulfilling the requirements of REACH, such as pre-registration or registration lies with the importers established in the European Union, or with the only representative of a non-EU manufacturer established in the European Union
So the next step is to analyse which roles does the company have.
Critical Business Issue
REACH requires those that manufacture or import substances into the EU to improve tracking and communication throughout the entire supply chain to ensure REACH compliance.
The consequences of REACH can span from the boardroom to the shop floor.
Efficient and proactive REACH compliance is essential to avoid:
• Losing your right to operation in the European Union (EU) market
• Sales disruptions (No Data = No Market)
• Strain on your critical vendor and customer relationships
• Non-compliant suppliers and unavailable substances
• Potential fines and loss of public confidence as a result of non-compliance
Some of the issues a company has to take care of when trying to be REACH Compliant span across different department and processes, which needs to be coordinated.
Some of the issues are:
- Which substances are affected?
- Which data elements are required for registration?
- What is the status of the exiting data elements?
- Which studies must be conducted?
- Did the vendor register?
- Are the registered substance volume limits sufficient?
- Does the non-EU vendor have a representative in the EU?
- Are all products registered?
- What are my customers’ use and exposure scenarios?
- What is the monetary value of a substance?
- Does the required data exist for all Recipes / Bills of Materials?
- Is our own exposure scenario registered?
- Are all input and output materials registered?
Regulatory Affairs / REACH Program Manager
- What is the status of the registration?
- Are manufacturing and purchasing in compliance?
- Have all required dossiers been sent to the ECA completely and in the correct format?
- What are the registration costs?
SAP REACH solution
To handle all issues which has to be taken care of according to the REACH legislation, SAP has created a solution in a holistic approach, which not alone covers the REACH legislation, but also other legislation’s like RoHS and a solution which are prepared to be extended if new legislation’s will arrive around in the world.
To get a basic knowledge about the SAP REACH solution, I have gathered some links: