July 26th, 2023

Understanding REACH in a Supply Chain Industry Context

REACH Lies at the Core of Effective Supply Chain Management 

For anyone working day-in, day-out in the transport and logistics sector, the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) regulation is one of the world’s most impactful product compliance regulations.

To remain relevant in the European market, products manufactured, sold, and imported within and outside the EU must be REACH-compliant.

As supply chain sustainability gains greater importance within Europe and the global market, REACH compliance will be a cornerstone of greater sustainability. Why?

By complying with REACH, manufacturers contribute to a more sustainable planet by strictly governing chemicals that could cause environmental and health hazards.

That’s why, in this article, we’ll examine how REACH and the supply chain industry intertwine and their relevance in the British, European and global markets.

If you work in supply chain operations, it’s crucial you know the basics at least, so let’s jump in!

REACH and the Supply Chain

Although the REACH Regulation was written partly to boost the European chemical industry’s sustainability (as well as competitive innovation), one of its goals is to protect human health and the environment from chemical risks and create sustainable supply chains.

A sustainable supply chain refers to companies’ efforts to consider the environmental and human impact of their products’ journey, from raw material sourcing to production, storage, delivery, and every transportation link.

As such, the relationship between REACH and supply chain sustainability can be characterised in two ways:

• Creating a sustainable supply chain
• Creating a supply chain that can deliver sustainable products

A supply chain built to deliver sustainable products delivers information to support sustainability and, more importantly, aims to substitute substances of very high concern (SVHCs) in products.

Supply chain information duties in summary

The duties and expectations at all stages of a REACH-compliant supply chain can be defined as follows:

A Producer / Importer is:

• Required to identify specific downstream users of a substance
• Prepare chemical safety assessments and recommend risk reduction measures
• Deliver a sustainable strategy to the Downstream user
• Expected to have the best knowledge of the chemical’s intrinsic properties
• Expected to poses good knowledge of the safety of the chemical and applicable risk reduction measures

The Downstream User then:

• Receives the sustainable strategy to verify/inform of the safe use of the chemical
• Is requested to inform the specific use of the chemical to the chemical suppliers
• Has to possess the best knowledge of how the chemical is used and the current risk management measures in place
• Requires pro-active communication towards the supplier
• Records the strategy for easy access

UK-EU Trade and Cooperation Agreement

Chemical and manufacturing industry stakeholders called for an agreement with the EU that ensured frictionless trade and regulatory consistency, ideally aligning as close as possible to REACH. The Trade and Cooperation Agreement between the UK and the EU contains an Annex on the trade, regulation, import, and export of chemicals.

UK authorities continue to benefit from the wide range of substance-centred information publicly available on the ECHA web pages. Following Brexit, ECHA only provides UK authorities access to data on a far lesser scale than EU Member State authorities that continue to interact directly.

UK REACH Explained

The UK REACH Regime was initially designed to establish a UK-wide market for chemicals, applying to all chemical substances manufactured and imported into the UK, with the Health and Safety Executive designated as the UK REACH Competent Agency.

The EU REACH Regulation continues to apply to Northern Ireland after Brexit. At the same time, UK REACH regulates the access of substances to the market in Great Britain, as set out in the REACH etc. (Amendment etc.) (EU Exit) Regulations 2020.

The UK REACH regime replicates the EU system as closely as possible, maintaining its fundamental aims and including high health and environmental protection standards.

The UK and EU REACH Compliance Requirements

The global markets must understand the REACH compliance requirements in depth before engaging in any business activity.

Below is a straightforward guide to keep you updated on the same:

Step 1: Product Information Collection and Analysis

The first step to complying with REACH regulations is to collect information on the properties and uses of the substances in the scope of the regulation that are manufactured in or imported into the EU/UK above one tonne a year.

There is no standard reporting template for REACH—Full Materials Declarations (FMDs), certificates, safety data sheets, and test reports are examples of valid information that suppliers can collect.
After data collection, companies must assess the hazards and potential risks posed by any chemical substance. This information is then shared with ECHA/HSE, as illustrated in the next step.

Step 2: Registration of Substances

The second step of EU/UK REACH compliance is registering substances via a registration dossier.

Registration dossiers contain substance hazard information, an assessment of the risks associated with those substances, and an indication of how the risks are managed.

Step 3: Registration Evaluation

After submission of a REACH registration dossier, ECHA/HSE evaluates whether the registration follows the requirements of the regulation.

The regulating body and a member state assess the quality of the registration dossiers and the testing proposals to clarify if a substance risks human health or the environment.

After the evaluation, companies may be required to submit additional information about specified substances.

Step 4: Ruling on Substances by ECHA/HSE

If ECHA/HSE discovers risks associated with using certain substances, those substances can be restricted, banned, or made reportable as Substances of Very High Concern (SVHCs).

That’s why SVHCs that are not restricted, banned, or authorised for specific purposes must be reported before being used in products.

Per REACH Article 33, companies must declare the presence of SVHCs at a concentration above 0.1% weight by weight (w/w) at the article level.

Companies are required to provide the names of any SVHCs present in their products, along with any safe use information for those substances. After companies complete this process, they can use the declared SVHCs.

Step 5: REACH Certification

The final step of REACH compliance is receiving certification- Authorisation. Once a REACH registration dossier is evaluated and authorised, ECHA/HSE issues a REACH certificate that displays a REACH registration number to prove compliance with the regulation.

The Post-Brexit Impact on British Industry

There are now more non-EU than EU workers in several sectors that previously relied on European citizens, demonstrating the Brexit effect and the impact of international events on immigration patterns.

According to Guardian analysis, non-EU workers surpassed their EU counterparts for the first time in 2022, at an average of 2.7 million, compared to 2.5 million workers in 2021.

Between 2019 and 2022, non-EU citizens employed in manufacturing grew by 23% compared with a simultaneous 5% decrease among EU staff. In arts and entertainment, the increase was 13% against a 12% fall in EU workers.

Various sectors that once relied on EU workers—such as accommodation and food services, admin, wholesale, retail, and vehicle repair – have shifted towards non-EU and British employees.

Other sectors like agriculture, forestry, and fishing still depend on EU workers but have witnessed changes.

About one in seven people employed in the industry sector in 2022 were EU citizens, a significant decline from 23% before the pandemic.

The proportion of non-EU workers has risen to 6%, compared with 2% in 2019 and 1% before the Brexit referendum.

According to the Pre-Brexit forecasts, industries that had previously relied heavily on EU workers would struggle to recruit migrant workers because most of the jobs were not considered skilled enough to qualify for the immigration system.

On the contrary, all major industries including the logistics industry have increased recruitment of non-EU workers, as evident in the number of non-EU citizens coming to the UK through non-work routes that allow them to work in any job recruitment.

Best Practices for Supply Chain Management and REACH Compliance

While there is no universal solution that fits every tier of every supply chain, there is an essential process that can (and should) be put in place for any supply chain that needs to comply with REACH.

Here’s a robust four-step process for ensuring effective, REACH-compliant supply chain management within your organisation:

1. Build or implement a central chemical database that can accept some kind of digital input from suppliers (i.e., a standardised spreadsheet every supplier can use or a shared online portal). There would be no better option to achieve this than contacting our experienced professionals to offer the needed database software information.
2. Ask your suppliers to provide as much data as possible via your new digital format and share the data with your clients similarly.
3. Refine and improve data sharing so that it is secure and accurate. Once you get your data-sharing system running, begin working to refine it so that you can see which chemicals are going into what you purchase and sell.
4. Aim for data sharing across the entire supply chain. Since REACH is ultimately a regulation that impacts entire supply chains, compliance is an interconnected effort.

Working With RollPallet UK to Build More Sustainable Products

RollPallet’s REACH solution deep-maps the supply chain to identify risks down to the consumer level. We go all out to provide our customers with all relevant information.

Whichever industry you are in, right from hotels that want to store excess baggage, retailers aiming to ensure the security of high value-items during shipping, pharmaceutical companies needing the guarantee of the safety of their pharmaceutical products, as well as office stationary companies requiring to safeguard the quality of their supplies, our Security Roll Pallets and Furniture Box 2500 Upholstery Pallet are REACH compliant, hence serving your needs.

To keep updated on REACH and the supply chain, please drop us a line today, and we’d be more than ready to support and advise you with as much information as possible to improve your operations and help you deliver better customer satisfaction.