MANUFACTURING REACH Regulation Compliance GAP Analysis and Action Plan for a Non-European Union Manufacturer Pumps, Valves and Seals Manufacturer, USA
REACH Regulation Compliance GAP Analysis and Action Plan for a Non-European Union Manufacturer Pumps, Valves and Seals Manufacturer, USA
Key Project Elements Manufacture of Pumps, Valves and Seals USA Based Manufacturer Supplying European Market European Legislation REACH Regulation EC/1907/2006 Regulation of Chemicals Regulation of Articles Bearing Chemicals Compliance GAP Analysis and Action Plan
CRA is providing a range of consultancy services to a pumps, valves and seals manufacturer based in the USA supplying the European market through direct and indirect customer supply routes. The REACH Regulation is a European Union (EU) regulation (EC/1907/2006) concerning the registration, evaluation, authorisation and restriction of chemicals st which came into force on 1 June 2007. The REACH Regulation is based on the premise that industry should be responsible for demonstrating that all chemicals put on the market do not have an adverse affect on human health or the wider environment. The REACH Regulation requires all manufacturers, producers and importers of affected substances at annual quantities of 1 metric tonne or more to register the substances. Substances of very high concern (SVHC) must also be notified to the European Chemicals Agency (ECHA) when present in products placed on the market at certain threshold concentrations, irrespective of the total tonnage involved. Articles bearing substances are also affected by the regulation. Importers and manufacturers of all manner of articles, including packaging materials, are therefore obliged to comply with the REACH Regulation. CRA was commissioned by a manufacturer of pumps, seals and valves to assist them in ensuring their European markets would not be negatively impacted by the implementation of the REACH Regulation. The client is based in the USA and supplies the European market through direct and indirect supply routes with products manufactured in the USA using a range of components and chemicals, including substances sourced from upstream non-USA based suppliers. CRA reviewed the upstream and downstream supply chain and the range of products and substances involved. CRA then performed a GAP analysis to identify areas requiring further assessment and developed a detailed action plan to enable the client to take a systematic approach to developing systems to ensure their products and supply chains could achieve and maintain compliance with the REACH Regulation. The action plan identified key steps to be taken, options available and, where appropriate, guidance on the implications for each option with respect to future REACH Regulation compliance.