REACH

Over the coming years all chemicals will be required to register under REACH, the new European Chemicals Legislation.

REACH – the Registration, Evaluation and Authorisation of Chemicals covers chemical substances, preparations & articles made or imported into the EU in quantities of 1 tonne per year. There are a few exceptions including

• Radioactive substances
• Those in transit
• Waste (as defined in EU Directives)
• Intermediates that only exist during an enclosed reaction.
• Certain human and veterinary medicines,
• Certain food and food additives

Without this completed registration it will not be possible to sell into the EU market.

By pre-registering your products you will be future-proofing your EU market share.

All existing chemicals will need to be pre-registered between 1^st June 2008 and 1^st December 2008 .

There are a number of challenges facing Non-European manufacturers and formulators as they may NOT register or pre-register their own products. The options available are

• Leave the registration to the importer – this is very burdensome for the customer
• Appoint an Only Representative to pre-register products.

Registration

With pre-registration in place, the registration process itself will begin from January 2009.

Registration may be a costly complex exercise and will depend which will depend on the volume and hazardous nature of the material. You will need a strong partner in Europe to manage this process, to represent your product at a European level.

Our Services

REACH Only Representative Services

By appointing Heterochem as your Only Representative

• European importers (your customers) of non-EU substances will be relieved from their obligation under REACH to act as registrants and will instead be regarded as downstream users.
• Heterochem will carry liability on your behalf assuming the manufacturer/importer responsibility to comply with all relevant obligations under REACH.

We offer a simple straightforward pre-registration service

1. June – Dec 2008:

• Cost effective pre-registration for each product you may wish to export into the EU.
• Ensure the quality and completeness of data to be submitted.
• Submission of the pre-registration file to ECHA
• Act as communication channel from you to the downstream user.

2. Jan 2009: Following the pre-registration process we will furnish you with:

• An analysis of similar substances pre-registered, by whom and for which end uses.
• An assessment for the scope for cooperation with others.
• Best advice on how to proceed with registration.

3. Late 2009: You decide if you wish to proceed with the registration process. At this point we will devise a proposal going forward. Our service initially is solely pre-registration however should you want us to manage your registration at this point we would be delighted to do so.

It is worth noting that once pre-registration is complete there is no obligation for you to remain with Heterochem; you have full entitlement to move to an alternative Only Representative.

Following the Pre-registration phase we can offer a number of additional services namely:

• Participation in SIEF, including contact and coordination with SIEF group members,
• Data exchange and evaluation,
• Negotiation with SIEF and Consortium members,
• Submission of registration applications,
• Collection and submission of technical dossiers,
• Creation and submission of safety data sheets,
• Creation and submission of chemical safety reports, (where required)
• Authorization negotiations with ECHA
• high-level discussions about risk assessments and use of information,
• notification to the ECHA of quantities of products manufactured/imported and related risk assessments,
• Communication concerning substances to downstream users.

• Heterochem have over 25 years experience of selling Chemicals in Europe .
• We are a well respected & established Chemical Importer & Distributor with numerous industry links.
• Our strengths in the following industries allow us to build upon our core competencies to work together with you to promote your products within Europe .
  • Building Chemicals
  • Pharmaceuticals
  • Plastics & Rubbers
  • Coatings
  • Cosmetic
  • Detergents
  • Food & Beverages
  • Water Treatment

We can turn this into a real business opportunity for you. By harnessing our market knowledge and combining it with your product offering you can increase your market share making REACH work for your company. We are your perfect partner in Europe .

1. ECHA website
2. REACH Regulation Legislation
3. REACH Regulation Legislation - Chinese
4. Guidance documents
5. Guidance on registration
6. Guidance on data sharing

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