Source: SPECIALIST PRINTING WORLDWIDE : ISSUE 4: 2010
Elaine Campling explains the compliance and responsibilities fast approaching with the REACH and CLP Regulation deadlines
The 1 December deadline for the first wave of REACH substance registrations is fast approaching and will be upon us some three weeks before Christmas! Higher hazard and larger volume (to the European market) substances must be REACH registered in this first wave, with tiered volume registration deadlines following in 2013 and 2018. Also, ahead of Christmas is the requirement for substances to be classified, labelled and packaged to the CLP Regulation from 1 December 2010.
It is often perceived to be manufacturers of chemical substances that have the primary REACH registration and CLP responsibilities. However, many importers (from outside the EU) will have REACH registration responsibilities and additional CLP duties. Failure to comply could disrupt supply and lead to prosecution. The coinciding timing of the REACH and CLP requirements is reported to be burdensome for larger organisations. The compliance capabilities at the SME (small, medium enterprise) level is, therefore, likely
to be troublesome, especially given that the scale of imports may be quite small, but nonetheless significant, such as that of a printer importing a range of printing inks, or chemicals for cleaning equipment from outside of the EU. The measure of success of the various campaigns to inform organisations of their duties on all levels, and consequently in judging the level of understanding from actual compliance, will undoubtedly become more evident as we progress through the REACH process.