REACH: Authorization Exemptions

ECHA has published some Q&A that might help some companies avoid authorization applications under REACH here

• Upstream activities are exempt if the end use is exempt.  E.g.:
• R&D – manufacturing and processing of chemicals for use in R&D
• Manufacture of a chemical on the authorization list is OK – it’s the use that may need authorization
• Medical device raw materials – if the medical device has no environmental concerns
• Fuels used in closed systems and the upstream activities

EHS Strategies, Inc. can help you identify how REACH impacts your products.