The European Union's new chemical regulation called REACH, "Registration, Evaluation, Authorisation and Restriction of Chemicals", is one of the most complex and detailed pieces of legislation ever brought into force in the EU. It requires all companies that manufacture in the EU or export to the EU chemical substances or items containing chemical substances above a certain annual volume, i.e., one tonne, to register these substances with the European Chemicals Agency (ECHA).
LRI Chemical's Complete REACH Services
LRI Chemical provides a complete list of services related to REACH, which includes (1) complete"Only Representative"services, (2) ad hoc research and consulting services, and (3) project management services, as shown in the following figure.
LRI Chemical's Complete "Only Representative" Services
From inventory review for pre-registration to facilitation at SIEF (Substance Information Exchange Forum) and subsequent report preparation, LRI Chemical can provide you with all the services required as an Only Representative relevant to REACH compliance. Our services include the following:
1. Substances Inventory Preparation
- LRI Chemical will review the inventory of substances or substances contained in the products manufactured in the EU or exported into the EU by a client.
- LRI Chemical will establish whether a client's products (substances including those contained in preparations and articles) will need to be registered under REACH, or whether they are exempt or do not fall under the provisions of REACH.
- LRI Chemical will compile and submit to the ECHA the requisite pre-registration information relating to any phase-in substances.
- Following pre-registration, LRI Chemical experts will take part in a SIEF on behalf of a client. LRI Chemical will, where necessary, request data from other participants or respond to the requests for data from other participants.
- For those substances with insufficient data to satisfy REACH requirements, LRI Chemical will research existing relevant data and identify the data gap.
- LRI Chemical will prepare Safety Data Sheets (SDSs) for every substance to be registered and manage the submission of a technical dossier, which includes toxicological and ecotoxicological study summary, via the International Uniform Chemical Information Database (IUCLID).
- For substances manufactured or imported in volumes exceeding 10 tonnes, LRI Chemical will gather and organise all data required and will compile it into the necessary Chemical Safety Reports (CSRs).
- In addition to the preparation of the separate submission including the company specific aspects of the registration, LRI Chemical will coordinate the common parts of a registration file, the so-called "joint submission".
- LRI Chemical will make necessary coordination in a consortium of substance producers and exporters if required by a client.
- LRI Chemical will assist in addressing any queries made by ECHA and recommend the best course of further action for a client.
LRI Chemical's service offering provides more than just Only Representative services. Using our full range of expertise and experience in chemical regulatory law, LRI Chemical can conduct research in many areas related to chemical regulation at country, international, and particularly European levels, e.g., EU Waste Directive and EU Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS). Similarly, leveraging our extensive network of researchers around the world, LRI Chemical is able to offer research services to cover almost any country. Using our tried and tested research methodology, we are also able to conduct comparative research of legislation in a range of countries. For example, we recently undertook a research project comparing legislation on safety data sheets in EU, UK, France, Italy and Germany.
We also offer helpdesk services to answer any enquiries related to chemical regulations:
+44-(0)20-7378-7300 (Dr Ryoko Matsuno)
Project Management Services
LRI Chemical can provide project management services beyond those required as an Only Representative, e.g., coordination with upstream companies in the client's supply chain. We can also provide project management services to clients, for whom we are not an Only Representative, which may include trouble shooting, management of professional services retained by them, etc. We include the third party representative services for EU companies in our project management services. We regard the REACH processes not only as a technical exercise but also as a task for which strong project management skills are vital.