Where are we with REACH? The European REACH regulation was implemented on 1 June 2007. The registration of substances began on 1 December 2008, and the next deadline is set on 31 May 2013. For you to get ready, here is some advice by the European Chemicals Agency (ECHA), responsible for REACH, as given during the 9th Congress on Perfumes and Cosmetics - Regulatory Issues, in Chartres, on 23 and 24 November 2011.
As a reminder, the reasons for
REACH
(Registration, Evaluation, Authorisation and Restriction of Chemicals) are many: at the same time, to increase knowledge on chemical substances, to better protect human health and the environment, while keeping the competitiveness of the European chemical industry and restricting animal testing.
Thus, cosmetic manufacturers, using chemicals, are affected by REACH: as manufacturers or importers, but, above all, as downstream users.
No data, no market
The implementation of REACH covers over ten years: passed by the European Parliament on 13 December 2006, entered into force six months later, it then offered six months for the pre-registration of substances (June to December 2008.)
The actual registration, based on the "no data, no market" principle, spreads on a schedule defined by volumes: from the largest ones to the smallest ones. REACH is based on the yearly tonnage, produced or imported into Europe, by legal entity (and not by company. For instance, in 2009, L’Oreal gave the figure of 40 legal entities.)
Just to clarify, a legal entity is a company that has a registered identity number (the SIREN number, in France, for instance.) Therefore, two subsidiaries come as two entities, while a branch linked to the head …
