Implementing REACH

Developing a successful way of working

To implement REACH successfully in your organisation, your main challenge will be to change the way you think. You need to make your staff aware that the products they market involve certain risks to people’s health and the environment. That is a major change.
The REACH regulation imposes a complex system of obligations concerning the registration of chemical substances and preparations contained in every product and appliance within the EU. To fulfil all of your obligations, you now need to know exactly who your client is, what your client does with your products, and whether you still want to supply that client. As a downstream user, your main interest is to know what your suppliers will do. Every time you use chemicals in your primary processes, you must consider the challenges imposed by REACH. Drastic changes in your procedures and culture may be hard to avoid.

Changes in your organisation

Many challenges are involved in the process of changing to the new way of working. You need to understand the strategic risks REACH imposes and fine-tune your organisation’s capacity for risk management and control. For example, you will want to actively avoid supply-chain problems and certain obligations; and some substances that you use may even be withdrawn from the market by producers because of the new REACH regulation. You have to keep up with your industry as you and your competitors prepare for REACH. What’s more, you need to map out the IT processes that govern your administration procedures and adjust them as and when necessary, just as all internal work procedures need to be adjusted effectively prior to deadline. The legislation will continue to change, so your administrative system has to be flexible in order to be able to keep up.

Three implementation phases

A structured, global implementation of REACH requires three phases:

1. Analysis of your portfolio and the REACH obligations
2. Assessment of the implications for all parts of your company
3. Selection of concrete actions that will embed your new obligations into your daily business

What can you expect from PwC?

PwC’s specialists can guide you through the entire process of implementing REACH within your organisation. We offer various services:

• Business Impact Assessment: We can conduct an assessment of your company with regard to the consequences of REACH for you and your current position in the implementation process.
• Only Representative scan: If you are a producer outside the EU exporting to the Community, we can assess the readiness of your company to appoint an Only Representative. This will relieve your customers from the registration burden and enable you to remain in control of your channel to the EU.
• Coaching: We can support the REACH manager or coordinator within your organisation throughout the implementation process.
• REACH Implementation Management: We can provide interim management to help implement REACH in your organisation.
• REACH Financial Management: We know that REACH poses an especially tough administrative challenge for those organisations that will have to register a large number of substances. We can help you maximise the benefits for your consortium in line with both your internal REACH accounting manual and specific consortium regulations on cost-sharing.

Event Identification Updating: We can track down and eliminate all REACH-related risks within your organisation.