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EU Regulatory Update: Deadlines Loom Under the EU REACH Legislation

Client Alert | 1 min read | 03.13.13

The EU REACH legislation establishes an integrated system for the registration, evaluation, authorization and restriction of chemical substances. It requires all companies (including US-based companies) which manufacture in, or import chemical substances into, the EU in quantities of one ton or more per year to register them with the European Chemicals Agency in Helsinki, Finland.

Companies which have pre-registered "phase-in" substances (which include those listed in the European Inventory of Existing Commercial Chemical Substances) benefit from extended registration deadlines. A May 31, 2013 deadline for registration applies to substances produced or imported into the EU in volumes of between 100 and 1000 tons per year per manufacturer or importer.

The REACH legislation requires that the EU member states introduce penalties for non-compliance with its provisions. For example, in the UK, national enforcement provisions provide maximum penalties of an unlimited fine and/or up to two years' imprisonment following conviction on indictment for relevant infringements.

Downstream users of chemical substances should check to ensure that their suppliers have registered the relevant substances. Otherwise, they will be unable to use un-registered substances which will be banned after the deadline.

In order to obtain assistance for compliance with the EU REACH legislation or any other EU regulatory issues, please contact one of the professionals listed below.

Insights

Client Alert | 6 min read | 05.02.24

DDTC Publishes Proposed ITAR Amendments to Enhance AUKUS Defense Trade

On May 1, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published a proposed rule that, if implemented, would streamline defense trade between and among Australia, the United Kingdom (UK), and the United States in furtherance of the trilateral security partnership (the “AUKUS” partnership). DDTC issued the proposed rule pursuant to new authorities and requirements contained in Section 1343 of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2024 which, in part, directs the Department of State to immediately implement an International Traffic in Arms Regulations (ITAR) exemption, subject to certain statutory limitations, for the UK and Australia if State determines and certifies that each has implemented (1) a system of export controls comparable to those of the United States and (2) a comparable exemption from its export controls for the United States. According to DDTC, the proposed rule “prepare[s] for a future exemption” and solicits public feedback “to shape a final rule following any positive certification.”...