A major international manufacturer of consumer products was assessing their regulatory obligations under REACH. Because of the nature of their business, their substance inventory was very large and the potential cost associated with achieving regulatory compliance was substantial.
Yordas Group examined the client’s inventory and found that a significant number of the substances listed were of natural origin (e.g. minerals and plant extracts). Depending on their hazard profiles and the specific conditions used to manufacture them, substances that occur in nature or are obtained from natural sources may be exempt from registration in accordance with Annex V of the REACH Regulation.
Manufacturing details and hazard data were obtained from the client for each substance that had been identified as a potential candidate for exemption. Yordas assessed this information and also performed detailed literature searches in order to fully evaluate each case. Where substances did fulfil the criteria specified in Annex V, exemption statements were created for the client that captured all the information necessary to demonstrate why registration was not required. Such documents are typically held on file by companies and may be provided to local regulatory authorities or actors in the relevant supply chains if requested.
By identifying the legitimate cases for exemption from registration, Yordas helped the client to significantly reduce the cost of achieving regulatory compliance.