REACh – A challenge for the European industry
The European Parliament resolution of December 2006 put on the statute books one of the most comprehensive and ambitious initiatives in the history of the EU: REACh. The acronym REACh stands for the registration, evaluation and authorization of chemicals. Many companies may be thinking that they are not affected by anything that concerns chemicals. However, the acronym is misleading. Contrary to initial expectations, REACh affects not only the chemical industry but also small and medium-sized enterprises which process the substances produced by the chemical industry. The objective of REACh is to ensure that substances are handled safely and responsibly throughout the entire value-added chain. All products produced and processed in the EU or imported into the EU are subject to this new directive.
The introduction of the new legislation involves a complete reversal of the burden of proof for the safe handling of chemicals within the European Union. On the basis of the principle of "no data – no market", the responsibility formerly held by the licensing authorities has been transferred to the industry. Companies themselves must identify and describe in detail the special risks involved in handling a substance. In addition, organizations must work together with end users to draw up detailed procedures covering the handling and application of substances, which must not then be used for purposes other than those specified.
A number of different players are involved in the implementation process. In addition to the individual companies which register their substances, there is a new central agency responsible for evaluating and authorizing substances, which is based in Helsinki. The task of the companies is to pass all the registration information in electronic form to this agency. The most important factor in ensuring the success of the registration and evaluation process is a complete record for each substance, which includes the ingredients, the risks they involve and the specific intended use of the substance. In order to identify the different intended uses, detailed communication is needed between the suppliers, including manufacturers, importers and customers ("downstream users"), throughout the entire value-added chain. The resulting data is used by the agency as the basis for evaluating and authorizing the substance. Once a substance has been successfully registered, this data must be processed by the agency in such a way as to provide transparent information for the general public on the use and the risks involved in using chemicals.
As the introduction process is very time-consuming and resource-intensive, it has been divided into three phases which are dependent on volumes and last for more than a decade. In order to make this gradual introduction process possible, substances must undergo pre-registration. Companies which do not submit their substances for pre-registration will not be permitted to manufacture or sell them until the end of the relevant registration phase.
Figure 1: REACh implementation schedule
Source: Brochure from the German Federal Ministry of Economics and Technology
The entry into force of REACh presents a particular challenge for companies' IT departments. A well-functioning infrastructure is an essential requirement for identifying and gathering information about substances which require registration. Without an analysis of the substances used in each product and their quantities, the process cannot run smoothly. A solution must be integrated into the existing IT architecture with interfaces to systems such as ERP, manufacturing and product development in order to obtain the necessary data from its original source. Developing these solutions will represent the major challenge for individual enterprises. The extensive administrative and strategic activities involved must be carefully planned. Support is available in the form of the implementation tools provided by the REACh agency and competent external service providers.
Future prospects
Contrary to first impressions, REACh offers significant future potential rather than simply representing a burden because of the extensive work it involves. Concerted action to implement this directive will enhance the image of the chemical industry and increase public trust in it. REACh should be seen as an opportunity for companies to market themselves and to stand out from the competition. Introducing an integrated and effective substance management system at an early stage will allow companies to consolidate their position as manufacturers, suppliers or importers and to attract new customers.