Cosmetics and DGSA Specialist
Phone +358 10 504 5860
satu.salomaki@chementors.eu
Finnish | English
Our EU REACH Consultant services can help your business ensure compliance with EU REACH regulations.
From REACH registration to REACH authorisation, our experts provide guidance and support to navigate the complex world of chemical regulations.
Contact us today to learn more.
REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) is a comprehensive set of regulations that govern the manufacture, import, and placing on the market of substances in the European Union (EU).
For enterprises that operate within the EU or do business with EU importers, it’s critical to ascertain that the products comply with REACH regulations. REACH regulation is a complex set of obligations that requires specific expertise to conduct the tasks precisely.
A REACH Consultant is an expert in EU REACH regulations who can provide a wide range of services to support companies in achieving and maintaining compliance status with these regulations.
We help your business navigate EU REACH regulations and achieve success in Europe.
Working in the field of REACH since 2012, Chementors has developed a service package based on the needs of the industry. We offer a complete set of REACH services which consists of:
As set out in the EU REACH regulation (EC) No. 1907/2006, REACH registration is a legal obligation placed on enterprises who manufacture or import substances as such or in mixtures into the EU market in quantities of one tonne or more per year. The registration process involves submitting a dossier that contains specific data about the substance to the European Chemicals Agency (ECHA) via the REACH-IT system. In general, the dossier should include information about substance identification profile, classification and labelling, physical and chemical properties, ecotoxicology, toxicology, and uses.
A REACH Consultant assists enterprises with comprehending the REACH registration process. Specifically, the consultant shall:
“With years of experience, Chementors is a qualified consultancy taking care of every part of the REACH registration process from A to Z on a turnkey basis.”
Phone +358 10 504 5860
satu.salomaki@chementors.eu
Finnish | English
Phone +84 39 6169 628
mi.nguyen@chementors.eu
English | Vietnamese
Phone +358 10 504 5862
prasanna.sakha@chementors.fi
English | Nepalese
Phone +358 10 504 5861
jan.nylund@chementors.eu
Finnish | Swedish | English | German
Compliance with EU REACH regulations is compulsory for companies operating within the EU. Failure to comply with these regulations can result in fines, harm business activities, and cause negative impacts on the company’s reputation. REACH compliance obligation involves ensuring that the products meet all requirements set out in the REACH regulation and maintain the compliance status at all times.
“Most importantly – we take all necessary action to fulfill any legal duty under REACH to guarantee the product is fully compliant for entering the EU market.”
For enterprises established outside the EU that would like to export products to the EU market, it is required to appoint an EU-based entity to act as their REACH Only Representative (OR).
The OR is a legal status under REACH regulation that shall work as the contact point between the non-EU entity and the authorities and shall represent the non-EU entity for all REACH obligations.
Chementors can operate as your Only Representative and handle all REACH duties for you and all your EU importers;
Chementors, with its headquarters in Finland, is an EU company. For more than a decade in the industry, we have been actively acting as an OR for manufacturers and suppliers based outside the EU.
“We are a qualified EU REACH Only Representative who meets all required and necessary criteria to manage REACH matters on behalf of non-EU enterprises.”
According to REACH (EC) No 1907/2006, substances of very high concern (SVHC) are those that:
SVHCs are included and periodically updated in the Candidate List published by ECHA.
If products contain any of these substances in the List, it is important to conduct a comprehensive SVHC assessment to make sure that the product is compliant with all legal requirements regarding SVHCs set in the EU regulation.
“Chementors provides a full set of SVHC services from SVHC compliance assessment to compliance certification. SVHC certificate is a strong communicative means which could be passed down to the supply chain for reference to prove the SVHC compliance status of the product.
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Certain SVHC substances in the Candidate List are subject to REACH Authorisation aiming to gradually replace those SVHCs with suitable substances or technologies which are safer for humans and the environment. Once included in the REACH Authorisation List, the uses of such substances in the EU market shall be restricted.
In case a product contains any of these substances, to start or continue using and placing the product on the EU market, enterprises must apply for a REACH Authorisation to ECHA.
EU authorities shall evaluate the application and decide whether the authorisation is granted or not.
We as a REACH Consultant will assist enterprises with comprehensively understanding the REACH Authorisation process, providing guidance on the information that needs to be included in the authorisation application, and handling the application submission tasks to ECHA.
Terms used in REACH regulation and registration process may not be very familiar to the majority. In this section, we introduce some keywords and their simplified definitions with the hope that it would help companies understand the REACH terms better. Please feel free to contact our experts for clearer information.
Chemical Safety Report For the registration of substances in the tonnage band of 10 tonnes or more per year, a Chemical Safety Report (CSR) must be submitted in the registration dossier. The CSR is compiled to demonstrate that the risks from exposure to the registered substance during its manufacture and use are controlled when specific operational conditions and risk management measures are applied.
Generally, a CSR consists of the following parts:
Consortium Registrants of the same substance could decide to establish a consortium generally to:
Inquiry dossier Before registering, potential registrants have a duty to inquire to ECHA whether a registration has already been submitted for that substance. Based on the submitted substance identity information in the Inquiry dossier, ECHA directs the inquirers to the relevant co-registrant’s page in REACH-IT. Only when having this decision from ECHA, the potential registrant can submit the registration dossier or start any tests on vertebrate animals if required.
Letter of Access (LoA) ECHA establishes a legal framework regarding the Joint Submission’s data-sharing obligation. For that, parties are required to share the cost of information that is required to be submitted as well as the administrative fee. A data-sharing agreement is mandatory and should be made in a fair, transparent, and non-discriminatory way.
By paying for a Letter of Access (LoA) to join the Joint Submission, the potential registrants should have access at least to the endpoint results for which they have paid or to a copy of the robust study summary and study summaries, if available.
This practice helps reduce registration costs and avoid unnecessary testing, especially on vertebrate animals.
In short, the LoA fee is:
Lead Registrant Under the REACH Regulation, the role of Lead Registrant is a mandatory role laid down in Article 11(1). The Lead Registrant is defined as the ‘one registrant acting with the agreement of the other assenting registrant(s)’ and is the one that must submit certain information first before others can submit their member dossiers.
The Lead Registrant must act with the agreement of the other co-registrants, submit the joint submission dossier as well as coordinate the activities within the Consortium.
Joint Submission Based on ECHA’s “one substance – one registration” principle, potential registrants are required to jointly submit information on their substance whose identification profile is the same as the substance that was already registered on the ECHA database. This process is called a Joint Submission. It helps enhance the efficiency of the registration system, reduce costs, and minimize testing on vertebrate animals.
Individual Submission For substances that have not yet been registered in the ECHA database, an individual submission is required.
Tonnage band The volume of the substance that was manufactured and/or imported shall be calculated in tons per calendar year which is from 1 January to 31 December. To do so, potential registrants need to sum up all volume of the substance on its own, in a mixture, and in an article intended to be released. The total estimated volume will then determine the tonnage band to be registered. There are four tonnage bands for registrations:
The tonnage band will have an impact on the ECHA fee, Letter of Access fee, and the amount of information to be provided in the registration dossier.
For manufacturers, suppliers, or importers who plan to place products in the European Union, it is essential to ascertain that the products always stay compliant with EU REACH regulations. REACH is a complex and ever-evolving system of regulations that govern the manufacture, placing on the market, or use of substances on their own, in mixtures, or articles in the EU.
To comply with these regulations, companies often find it efficient to cooperate with an EU REACH consultant who can handle all REACH issues. Due to the importance of REACH compliance to the business, finding a qualified EU REACH consultant is essential. This article will provide general ideas and a checklist to answer that question.
One of the very first criteria to focus on when searching for a REACH consulting agent is their qualifications and experience. REACH compliance is a technical duty that requires both specific know-how and a wide range of expertise. Therefore, companies should invest time to check and consider working with a consultant who has a team of sufficient backgrounds and extensive experience in REACH regulation. A consultant with relevant academic qualifications who has been actively working in the field for several years is a prospective candidate.
Generally, a REACH consultant should possess an in-house team of experts having strong backgrounds in all these fields:
✔ Chemistry
✔ Biochemistry
✔ Toxicology
✔ EU chemical regulations
✔ Economics
✔ Practical industrial experience
The next step is to learn about the consultant’s reputation. Do search for references and reviews from their past and current customers. If possible, discuss with other enterprises in your network who have worked with the consultant to gather general evaluation. It is recommended to partner with a consultant who has a good track record in REACH matters and good reviews about reliability, efficiency, and professionalism.
In addition, it is also a good indicator of reliability if that consultant is a certified member of a known association in the REACH field since this often implies that the consultant has met certain quality criteria set by the association.
Communication is a key factor when working with a REACH consultant. REACH is a complex legislation that comprises of different small tasks and, as a result, would raise many questions. Therefore, to have the whole process run efficiently with less impact on the business plan, it is highly recommended to work with a consultant who can provide flexible communication ways to respond actively to your inquiries.
Also, the consultant should be able to provide answers and understandably present the project strategy. Fluency in the English language and “REACH language” is a core indicator for this criterion.
During the initial consultation phase with a potential candidate, it is good to pay attention to how that consultant communicates and how they respond to a specific question.
Due to the complexity of the regulation, REACH compliance obligation is not a one-size-fits-all process. Each project often has specific characteristics, different objectives, and a different set of data to fulfill. As a result, enterprises often prefer to collaborate with a consultant that can provide a service package that is customized to project-specific needs. A tailored service would ensure that all aspects of the project are treated carefully on an individual basis.
Before making the decision, do go through all offer details to clearly comprehend what will be delivered and when. Checking the pricing structure will also help identify if the consultant can do the whole work or only parts of it.
It is important to note that, under REACH regulation, the compliance obligations do not finish at a particular milestone. For example, after the registration is done, companies are still fully responsible for monitoring all notifications from the authority and consortium and acting immediately without undue delay.
Therefore, to maintain the compliance status of products, choose to work with a consulting partner who can also cover the follow-up work, so that companies could focus on their business activities.
When looking for an EU REACH consultant, there are some critical mistakes to avoid:
Not assessing the qualifications: To ensure the quality of the work, it’s critical to verify if the consultant owns relevant backgrounds and experience in REACH regulations. When needed, do ask for the qualifications of experts who will handle the project.
Selecting based solely on price: While it’s important to go with a solution that fits the project budget, choosing solely based on price could eventually cost more. An overly general offer may not cover project-specific needs. If a consultant is only able to handle a part of the project, this may result in a need to hire other service providers to manage other tasks. Lacking the required expertise and experience would cause a negative impact on the quality of the whole work, as well as the compliance status of the product, and consequently harm business activities and company reputation.
Therefore, do evaluate all possible aspects to select the right one.
Not asking about the plan: Unclear about the plan right from the beginning could cause misunderstandings and potential troubles later. To ensure the work stays aligned with the project’s objective and expectations, you should discuss and be clear about the work plan including the scope of the work, details of tasks, solutions/methodology, timelines, and deliverables.
Not evaluating the team’s capacity and competency: Irrelevant or insufficient expertise and lack of human resources will have a significant impact on the quality of the work and the timeline of the project.
Therefore, it is advised to carefully verify the competency and capacity of the consultant. Asking for a qualification profile of experts who will handle the project is also a good practice.
Selecting a trusted and qualified EU-REACH consultant is a critical step to rest assured that product compliance is well taken care of. Therefore, do consider all possible criteria and avoid common mistakes.
We Chementors are confident to be a qualified REACH consultant partner for EU and non-EU companies:
✔ Chementors has been active in the REACH field for over 10 years.
✔ A team of competent experts is our core strength. We have people with strong backgrounds and years of expertise in chemistry, toxicology, and chemical regulatory fields to manage all REACH aspects. Some of our members are former experts at ECHA, and our owners have also been running chemical industry factories.
✔ We continue to receive good feedback from our clients.
✔ Communication skills are our advantage. We are highly fluent in English language and the “REACH language”. We also speak other languages: Finnish, Swedish, French, German, Nepalese, and Vietnamese.
✔ A tailored REACH service on an individual basis is one of our competitiveness.
✔ We handle all REACH-related tasks.
Our team is located in Europe and Asia, so we are nearby to assist companies with REACH matters.
REACH (EC) No. 1907/2006 is a chemical regulation developed by the European Union concerning the registration, evaluation, authorisation, and restriction of chemicals. It came into force in 2007.
Under the REACH regulation, all substances, either on their own or in mixtures, with certain exceptions, are subject to a registration obligation if they are manufactured, imported, or placed on the EU market in quantities of more than one tonne per year.
REACH compliance is a legal obligation. Under REACH, depending on the activities in the supply chain, a legal entity may have separate roles with corresponding REACH responsibilities to fulfill. Failing to comply with REACH could result in penalties, legal troubles, a stop of sales, and reputation damages.
REACH regulation places the registration obligations on the following actors:
Depending on the supply chain model, a legal entity shall be classified as a manufacturer, importer, or downstream user following the definition set in Article 3 of the REACH regulation. It is also possible that one entity takes multi roles, such as both manufacturer and importer roles, for the same substance. Each role will correspond to a set of REACH requirements. Therefore, it is critical to correctly verify the role of each substance.
EU REACH is a complex and ever-evolving set of regulations that require specific competency, i.e., relevant backgrounds and in-depth REACH experience, to handle the tasks precisely.
To comply with REACH regulations, enterprises often find it efficient to cooperate with an EU REACH consultant who can cover all REACH matters on a turnkey basis. This allows companies to focus resources on business matters.
Due to the importance of REACH compliance to the business and company reputation, it is critical to select a competent EU REACH consultant
A REACH consultant manages all REACH matters by:
To maintain smooth manufacturing and importing activities, it is very important to ascertain that the product always stays compliant with the REACH regulation. A few good practices are:
Customer inquiries
Phone +358 44 974 0601
Address: Chementors Oy, Smart Chemistry Park, Raisionkaari 55, FI-21200, Raisio, Finland
Email: rebecca.karjalainen@chementors.fi
Finnish | English | French
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We appreciate your patience and will get back to you as soon as possible.
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Best regards,
The Chementors Team