24 March 15

The Life + inREACH Project and the impacts of the REACH Regulation on the Supply Chain

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REACH (Registration, Evaluation, Authorization and Restriction of CHemicals) is the Regulation CE 1907/2006 defining a new integrated system that, by means of a single law, replaces much of the legislation in the field of Chemicals. This Regulation involves different actors along the Supply Chain, from the Manufacturer to the Consumer, from Companies to Enforcement Authorities, and it is relevant to the Import process for Chemicals (substances, mixtures or articles) entering the European Economic Area (EAA). REACH has as primary goal the protection of both human health and environment and it wants to achieve it by forcing companies that manufacture or import chemicals into the EEA to evaluate and manage risks that can originate from their use and to prove their safety.

Since the very beginning of its implementation, REACH came along with criticalities in the definition of every single actor involved in the Import process and the related allocation of responsibilities (while it sounds good on paper). There are relevant problems in establishing liability in relation to the marketing and use of dangerous substances and in ensuring that producers assume responsibility for their products. Connections between cause and resulting damage could not be made in the absence of adequate test data on the effects of substances. Indeed, a great amount of information on chemical substances has to be provided by importers and transferred through the Supply Chain as requested by the Regulation today.

The inREACH Project is part of this context. Started in September 2014, with a foreseen 36 months duration, a total eligible cost of € 801.034 and co-founded by the Life+ program (Financial Instrument for the Environment) of the European Commission with a contribution of € 400.517, the Project is coordinated by the TICASS Consortium (Managing Body of the “Energy-Environment” Regional Innovation Hub for Regione Liguria) with Federchimica, Istituto di ricerche farmacologiche “Mario Negri” and Centro REACH as Associated Beneficiaries.

During its activities inREACH will deliver a State of the Art of the impacts on the Supply Chain of the REACH Regulation implementation, and will provide different solutions to overcome the most Critical Issues  encountered along the way, deploying the “inREACH Framework” (Guided procedures and supporting ICT tools) and testing it by means of several Demonstration Activities, involving Public and Private Stakeholders (Extra EU Manufacturers, Importers, end-users, Freight Forwarders, Enforcement Authorities).

An agreement has already been signed with Italian Agenzia delle Dogane e dei Monopoli for cooperation in the context of the project (analysis phase). Italian Ministero della Salute and Ministero dello Sviluppo Economico supported actively the Project from the very beginning, together with national associations as AssICC – Associazione Italiana Commercio Chimico and Fedespedi, which contributed with useful information to the realization of a proper Specific project Report.

inREACH will support the protection of the environment and human health by facilitating the exchange of information on substances, mixtures and articles classified from the point of view of their chemistry composition, in the process of importing from countries outside the European Union and the definition of the arrangements for monitoring their compliance with the REACH Regulation. In order to achieve its primary goal, communication along the Supply Chain and a sound information flow are necessary for all the Stakeholders involved, for Downstream Users in terms of completeness and accessibility of information, and for Enforcement Authorities in term of integration (not duplication) of existing information accessible via ICT systems.

To date, inREACH carried out preliminary activities such as the setup of a Stakeholders Forum and an analysis phase focused on what has been done since the implementation of the REACH Regulation. This investigation phase led to a deep knowledge of issues and criticalities that actors involved encountered while carrying out the necessary operations in order to ensure compliance with REACH. The 5 topics core for this State of the Art are Regulation (European and National laws), actual procedures and technologies supporting REACH Regulation implementation, definition of standardized Sampling Protocols for REACH analyses, impacts on the Supply Chain, science-Politics integration. For each one 5 main critical issues have been identified and for every one there is a proposal for a possible solution part of a wider Road Map, that will help, with the implementation of innovative solutions, to overcome the Critical Issues encountered. In a later stage starting on June 2015, the demonstration activities foreseen by the Project will start with the help and implication of stakeholders.  After the Demonstration phase, the Project will end with the release of the framework mentioned before, with the goal that it will represent an helpful tool for companies, especially for SMEs, involved in this sector.

A line is open with Stakeholders by means of questionnaires (available on project web site – www.inreachproject.eu), interviews, newsletters in order to collect “first-hand” information and ensure a proper operative approach.