Richard Hawkins, chemical policy advisor at the Environment Agency (EA), told printweek.com: "Basically, printers need to ensure that the suppliers of the substances they use have taken REACH into account... If a printer imports a substance that is not regulated for use by REACH and is restricted in its use, then [legal] action could be taken."
The EA, which has the power to enforce against polluters, has been involved with REACH from its inception and worked with Defra(Department for Environment, Food and Rural Affairs) in negotiations regarding the legislation. REACH is a set of EU rules governing the registration, evaluation, authorisation and restriction of chemicals, which came into force on 1 June last year. It replaces a number of European directives and regulations with a single system.
In order to comply, manufacturers have just eight months from now to register or pre-register the chemicals they produce. This includes stipulating the uses various chemicals are put to, such as ingredients in inks and cleaning agents. Failure to comply will lead to those substances being banned from industrial use.
"Printers have to be aware that they need to take this seriously," Hawkins added. "Especially the people that use dyes and inks; these are significant users of chemicals. They need to go back to their suppliers and ask if, as far as REACH is concerned, are these chemicals compliant?"
Low awareness, high risk
PricewaterhouseCoopers this month published a survey called Waking up to REACH, which found that two in five companies have limited awareness of the legislation. The firm surveyed 241 senior executives across six industries, including paper and packaging, and found that one in four executives feel that REACH will have no impact on their operations.
Simon Taylor, a consultant at PWC, told printweek.com: "Some sectors are, by and large, well prepared. But the survey also shows that others are a little behind.
"The printing industry is a relatively heavy user of chemicals in terms of the number of substances, because inks and printing agents are preparations using many different substances. If a chemical does not comply, then there is potentially a legal problem," Taylor added. "It's certainly a commercially risky situation."
However, the EA's Hawkins stresses that a certain degree of leniency will be necessary on the basis that this is new legislation. "As an authority, we take a reasonable, balanced approach," he said.
Despite a number of calls and emails and assurances to the contrary, industry body the BPIF did not or was not able to respond to printweek.com's questions regarding REACH.
The EU estimates that there are 30,000 substances on the European market manufactured in quantities of one tonne or more every year. The process of registering all of these at once would have been a huge task. So registration will take place over three phases spread over a period of 11 years.
However, substance manufacturers that do not pre-register their chemicals by the end of November this year, must fully register their substance on the 1 December or face breaching European law.
"The key thing is for downstream users such as printers to make sure their suppliers know the use that they put a particular chemical to," Taylor said. "The critical issue to downstream users is to have effective dialogue with their suppliers. It's about them feeling comfortable that they will comply."
Responsibility for implementing REACH in the UK is handled by the Health and Safety Executive and its website carries a section containing comprehensive information on the legislation (www.hse.gov.uk/reach).
PWC's Waking up to REACH is also available online (www.pwc.com/chemicals ).
