REACH registration obligations are based on two main principles. Each substance that’s imported or manufactured in Europe must be accounted for, but only once. If a single entity is responsible for more than one ton per year of a substance, it must register that substance.
When a cosmetic product is imported into Europe, the quantities of each substance must be calculated and the entity responsible for it must be identified.
Biorius offers a full REACH audit service to help you identify your responsibilities and communicate your substance status along the supply chain. This process is completed through the following four main services:
1. Identification of your substances of interest:
This step identifies the substances in your products, calculates their tonnage and assesses whether these substances require registration under REACH through:
- Identification of the product portfolio placed on the European market and total breakdown of this product portfolio regarding its substances
- Calculation of the substance-specific tonnages based on European annual sales or imports
- Evaluation of registration exemption
2. Investigation of Reach status:
Depending on your position in the supply chain, a portion or the totality of your “registrable” substance quantities may already have been accounted for in a REACH dossier. Biorius can investigate the status of each substance contained in your products:
- Communication with upstream members of the supply chain (i.e., brands/manufacturers/ingredient suppliers) to assess the REACH status of each substance
- For substances already accounted for in a REACH dossier, Biorius will collect the appropriate information and documentation for communication with partners or authorities in the event of inspection.
3. Evaluation of potential regulatory actions:
Based on the results of the previous steps, one or more plans of action will be proposed by BIORIUS for each substance. The proposals will be specifically tailored to your situation and can range from a simple certificate edition to the registration of substances.
4. Representative of the client with supply chain partners:
BIORIUS can act as your representative with respect to your supply chain partners to help you fulfill your regulatory obligations and negotiate cost sharing.
In the event of registration, BIORIUS can act as your “Only representative” if you are based outside Europe or as your counsel if you are based within Europe.