RPA has extensive experience and expertise in helping clients manage their regulatory and compliance risks and obligations under REACH and other chemical regulations. We support industry organisations (individual companies, consortia, associations) in complying with their REACH duties and developing strategies for addressing future regulatory challenges.
REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. The REACH Regulation (Regulation (EC) No 1907/2006) revolutionised the way the marketing and use of chemicals is regulated in the European Union. Since the United Kingdom left the EU in 2020, UK REACH applies in Great Britain, while Northern Ireland continues to use EU REACH.
The REACH regulation lays down specific duties and obligations on manufacturers, importers and downstream users of substances on their own, in mixtures and in articles. It is based on the principle that industry should manufacture, import, use or place on the market substances with such responsibility and care as may be required to ensure that, under reasonably foreseeable conditions, human health and the environment are not adversely affected.
In October 2020 the European Commission announced, in the Chemicals Strategy for Sustainability (CSS), a revision of REACH. To support the impact assessment of this revision, nine EC supporting studies have reported on various topics of REACH, and RPA has been involved in several of these studies.
We are providing REACH services to a variety of clients with a focus on REACH Authorisations and Restrictions. We have supported over 50 industry clients and several industry consortia with their authorisation dossiers for over 15 substances covering 75 plus uses.
We employ an experienced and expert chemicals team, comprising chemists, toxicologists and chemical engineers who are supported by economists and environment experts to cover all aspects of a chemical’s lifecycle. Having successfully supported ECHA, national competent authorities and industrial clients, we have developed a detailed, tried-and-tested methodology for collecting and analysing data, developing coherent and robust arguments, and preparing the necessary dossiers and reports according to ECHA’s specifications and guidance documents.
We were involved in the preparatory work for REACH, from the publication of the White Paper in 2001 through to agreement of the final provisions of the Regulation. We were also involved in several REACH Implementation Projects and have prepared guidance for DG Environment on assessing health and environmental impacts to support REACH Authorisation or Restriction proposals.
We are recognised experts in socio-economic analysis and chemical risk management. We complement our in-house team with recognised experts from other specialist organisations with whom we have long standing relationships.
The types of REACH-related services offered include:
For industry clients (including trade associations and special interest consortia) we provide analytical, strategic and advisory services including:
- Applications for Authorisation
- Authorisation Review Reports
- Submissions for REACH Restriction
- Analysis of alternatives
- Socio-economic analyses
- Writing and communication of substitution plans
- Supply chain engagement and communication
- Project management services
- Scoping/horizon scanning services
- Updates to registration Chemical Safety Reports (in association with leading experts in the field of risk assessment)
- IUCLID submission
- Provision of training
For authorities and public bodies, we provide analytical and advisory skills in relation to:
- Market analyses for Annex XV dossiers (SVHC and Restrictions)
- Analyses of alternatives for Annex XV dossiers (SVHC and Restrictions)
- Development of guidance for the implementation of REACH requirements
- Provision of training