REACH Update

REACH legislation is evolving all the time, as is its effect on our industry. Big changes will be coming over the next few years, so make sure to keep up to date. REACH applies to all chemicals that are marketed or manufactured in the European Union, with few exceptions.

Cosmetics, beauty and personal care products are considered to be “preparations”, and each preparation imported in greater than 1 ton metric per year must be registered by either the EU manufacturer or importer. If any ingredient found in such preparations is not registered (and exceeds the threshold limit), the importer into the EU is responsible for registration. The importer must be a naturalized or legal person established within the EU and responsible for the importation and adherence with all REACH obligations (called an “only” representative).

The only exemption for cosmetics and personal care products from REACH obligations is that MSDS for these products are not required to be provided to the consumer, but will be required by those who use these products in a professional setting, i.e. salon or spa.

REACH regulation implementation is scheduled to take place over the next 10-15 years.

June 1, 2007 – new Safety Data Sheets (SDSs) must be prepared according to the new REACH format.
December 1, 2008 – manufacturers and importers must have pre-registered all chemical substances.
December 1, 2010 – manufacturers and importers must have registered phasing substances over 1000 metric tons/per year plus “CMR substances” and “toxic substances” over 1 ton per year.
December 1, 2013 – manufacturers and importers must have registered “phase in” (not pre-registered) substances over 100 metric tons per year.
December 1, 2018 – manufactures importers must have registered “phase-in” substances over 1 metric ton per year.