Your specific business activities will determine what you have to do to comply with the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. The requirements of REACH often have to be decided on a case-by-case basis. You need to be able to justify the actions that you take. To help you do this, you should document the reasons for your decisions, in case you are challenged.
You may use chemicals for a range of purposes, including paper production and cleaning. You must store and handle chemicals safely to avoid pollution incidents and health risks. Regularly review the hazardous substances you use, make sure you follow any restriction or controls placed on them and where possible use less harmful alternatives.
Does REACH apply to your paper manufacturing business?
The REACH Regulation aims to protect human health and the environment through the control of chemical substances.
If you use, supply or manufacture chemical substances, or import them from outside the European Union (EU), it is likely REACH will affect you in some way.
REACH applies to a wide range of chemical substances on their own, and in preparations or mixtures including coatings, paints, varnishes, inks or dyes and cleaning products. REACH also applies to chemical substances contained in finished products or articles, whether you are manufacturing or supplying them within the EU, or importing them from outside the EU.
Paper is classed as an article under the REACH Regulation.
Chemical users' requirements
You are a chemical user if as a part of your work you:
- use any chemicals or preparations
- use chemicals to formulate or blend preparations or mixtures
- use any chemicals, preparations or mixtures to produce articles
If you use a chemical substance, you must:
- identify and follow all appropriate safety measures identified by the chemical's safety data sheet
- use the substance within its safe exposure limits
- comply with any conditions of authorisation that have been placed on its use by REACH
- not use it in a way that is restricted by REACH
You should check that your suppliers register all the ways you use the chemicals they supply. If you have an unusual use for a substance, you should provide your suppliers with details of how you intend to use the chemical. This will allow them to include this information in their registration. If you do not want to tell your suppliers about your use for a chemical, you may have to carry out a chemical safety assessment for that substance, and submit your assessment directly to the European Chemicals Agency (ECHA).
You should make an inventory or list of chemical substances that your business uses, supplies, manufactures or imports. This will help you understand your responsibilities and the impact REACH will have on your business activities.
Substances of very high concern and restricted chemicals controls
REACH places controls on the supply and use of certain chemical substances on their own, in preparations or mixtures, or in articles. These apply to substances that can be particularly harmful to human health or the environment, for example those that are classified as persistent, bioaccumulative and toxic (PBT).
There are three groups of chemicals that are specifically controlled under REACH:
- the candidate list of substances of very high concern (SVHCs)
- Annex XIV substances - priority SVHCs that require an authorisation for their supply and use
- Annex XVII substances - particular chemicals with restrictions on their supply and use
If you supply or use a chemical substance, on its own, in preparations or mixtures or in articles, make sure that you meet any specific controls that apply to it.
Manufacturing, importing and distributing chemicals
If you manufacture, import or supply chemical substances there are additional REACH responsibilities that you must comply with - see registration, evaluation, authorisation and restriction of chemicals (REACH).
If you manufacture or import chemical substances, products or mixtures you must classify and label them correctly before you put them on the market.