1. Home
  2. |Insights
  3. |EU Regulatory Update: Deadlines Loom Under the EU REACH Legislation

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 | 3 min read | 06.12.26

DOJ Guidance Backs Away From Disparate Impact Liability

On June 9, 2026, the U.S. Department of Justice (DOJ) issued a formal opinion concluding that the Equal Opportunity Employment Commission’s (EEOC) existing interpretations of Title VII of the Civil Rights Act of 1964 (Title VII) disparate-impact liability, including the Uniform Guidelines on Employee Selection Procedures (UGESP), are unconstitutional. According to the opinion, EEOC’s prior interpretations contemplate liability based on disproportionately adverse effects alone, without regard to an employer’s likely intent, rather than treating disparate impact as an evidentiary mechanism to “smoke out” intentional discrimination. DOJ found that this approach functions as a “qualified racial-proportionality mandate” that places “a racial thumb on the scales, often requiring employers to evaluate the racial outcomes of their policies, and to make decisions based on (because of) those racial outcomes.” The opinion fulfills one mandate of Executive Order 14281, which rejected disparate-impact liability insofar as it “creates a near insurmountable presumption that unlawful discrimination exists wherever there are any differences in outcomes among different [demographic groups].”...