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Driven by proactive European Union regulatory mindsets, regulations are requiring affirmative registration as a condition for shipping and selling manufactured products. A current “ticking clock” is represented by REACH (Registration, Evaluation and Authorisation of Chemicals). This requires pre-registration by 12-1-08 which earns an 18 month “grace period” during which manufacturers provide rigorous compliance demonstration. Most companies have not met those pre registration requirements, and will face a requirement to prove compliance in 2009 - - with no grace period.
This REACH regulation alone could bring an exporting manufacturer to its virtual knees, and it is just the tip of a regulatory iceberg which is going to require new attention at the top of your company’s decision pyramid - - no longer “just” an environmental department problem.
In order to adress these and other REACH compliance issues, Green EcoSystems Group offers a comprehensive set of REACH solutions that include software tools, planning and implementation services. Key areas addressed by our solutions include: #1- Determining what the REACH regulation requires The REACH Directive is 849 pages long and replaces approximately 40 previous laws. As such, its requirements are complex, confusing and potentially costly. Failure to comply could result in fines, product bans and/ or loss of customer contracts. Minimally, companies need to gather and manage new categories of data and could face supply chain and other business disruptions in regard to substances they use. Deliverable: provide companies with a clear, understandable overview of REACH’s risks and requirements. #2- Determining what the implications are for typical companies Based on pre-liminary interviews and research, REACH specific action plans will be developed for companies especially those located in North America. For example: there are different implications depending on whether a company manufactures substances or imports them into the EU; formulates preparations; and/or is a Downstream User of substances that are included in articles sold into the EU. Also, there are different business decisions based on the types of substances used; the degree of knowledge a company has about substances in parts purchased from suppliers; and the usage of published substances that are likely to be restricted or banned starting in 2010. Deliverable: analyze the implications and develop company specific action plans. #3- Determining what could/should your company do: a. Protect its markets and revenue? b. Comply with REACH’s Pre-registration phase starting June 1, 2008? c. Set the foundation in place for future REACH phases?
Given that REACH’s Pre-registration period begins in June 2008, there are a number of internal data-gathering and external communication activities that companies should begin or accelerate immediately. The scope of these activities increases sharply, depending on, for example, the number of different articles sold into Europe, the number of facilities manufacturing those articles, and the number of chemical and component suppliers.
Deliverable: development of a REACH compliance roadmap with specific tasks, responsibilities and timelines.
#4- Implementing REACH Compliance Management Software Manufacturing companies of all sizes throughout the supply chain should implement REACH compliance mangement software to prove due diligence, comply with customer audits and to maintain documentation for the REACH required 10 year time period. Deliverable: Green-EcoSystem (Green-ES) to cost effectively manage REACH’s voluminous legal and business reporting requirements, including analyzing the risk associated with supply chain/business disruptions expected to occur under REACH. For more information on all of Green Eco System's REACH products and services, please contact us at:
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REACH Services
