By | October 26, 2020

In May 2018, the European Union Registration, Evaluation, Authorization and Restriction of Chemicals, better known as the REACH regulation, went into full effect.

This regulation, enacted in 2007, requires companies to register all substances with the European Chemicals Agency (ECHA) when the chemicals in the products they manufacture or import to the EU exceeds a designated threshold. As part of the Substance Volume Tracking (SVT) requirements, the bar was initially set at 1,000 tons but was lowered to 100 tons in 2013.

This year, the volume of a listed chemical that needs to be tracked dropped to a mere 1 ton, which complicates matters exponentially. Companies that previously weren’t required to track their substances will have to do so going forward. It also adds a new potential headache for companies that think they’ll be close to the new threshold but aren’t sure if they are going to surpass it.

Penalties for noncompliance can be quite dramatic. Each EU country sets its own penalties for noncompliance, but some are quite steep. Take Belgium for example. According to the 2010 final report on REACH, the maximum penalty in the Western European country including criminal sanctions related to the infringement of REACH requirements such as SVT is a robust 55 million euros (about $64 million) at the federal level.

 

Sphera’s Take

“Companies that pre-registered their substances from the outset of REACH benefited from the phased-in deadlines for registration, but companies that did not pre-register are required to register immediately any substance that is manufactured or imported in a quantity of more than 1 ton. An SVT solution can help ensure compliance by tracking volume trends with alerts tied to regulatory thresholds and facilitate scheduled and on-demand reporting rather than having to wait to extract information on an annual or biannual basis. It also can be used as a tool in a company’s Management of Change program for the chemical process industries.”