• Environmental

• Chemicals

REACH Compliance

Beveridge & Diamond, P.C. has closely followed the development and implementation of REACH, which falls at the intersection of two of our strongest environmental practices (chemicals and international environmental law). Our primary focus to date has been on REACH’s implications for non-EU manufacturers, although even our non-European clients typically have one or more facilities in the EU and we are therefore also familiar with the obligations on EU manufacturing.   

We have provided REACH compliance advice to U.S.-based multinationals in several sectors:

• For example, we assisted a major global pharmaceutical company evaluate its REACH exposure and helped it to develop a REACH compliance strategy for issues ranging from registration obligations for various chemical inputs at different stages of the pharmaceutical production cycle to the rules regarding "only representatives.”

• We provide ongoing advice to companies in the electronics sector with respect to supply chain due diligence strategies to address the potential for “substances of very high concern” in manufactured "articles" being imported into the EU.

• We represent chemical manufacturing interests that face a number of REACH compliance issues, both with respect to exports to the EU as well as EU manufacturing.

As a result of our prior and ongoing work for existing clients, and due to our active monitoring of continuing developments relating to evolving guidance from the European Chemicals Agency and member state inputs, we are familiar with the basic Regulation and many of its more complex nuances.  We are also conscious of cross-sectoral benchmarking and standard-setting efforts under way in the United States manufacturing sector to address the supply chain communication and disclosure challenges that REACH presents.  In addition, because of Beveridge & Diamond’s deep experience with every aspect of  data rights issues under analogous U.S. regulatory schemes, we have unique insights into complex data rights issues associated with the data compensation provisions of REACH and establishment and implementation of the related data development consortia that REACH mandates. 

We have partnered with local counsel in the EU to assist us on particular REACH matters where local knowledge is required or to confirm our own analyses where appropriate, and our clients have found that our ability to tap local counsel for discreet, targeted issues provides a cost-effective model for many elements of their REACH compliance and planning requirements.