Consultancy in Regulatory Affairs is Sitmae’s origin.
 
We help industrial companies comply with REACH and we lobby new legislation in Brussels on behalf of industrial trade associations. We have a distinct preference for technically complicated subjects. We were involved in REACH from its earliest conception.
 
As REACH consultants we have prepared a ‘REACH Roadmap’ for the members of six European trade associations. This document describes how to prepare their companies for REACH.

Our REACH consultancy covers:
 
• Complex REACH registrations
 
• REACH compliance in companies
 
• REACH compliance for complex articles
 
• Industrial advocacy: REACH review and REACH revision

Most registrations are ‘joint submissions’. This is OK in the majority of cases.
 
Sometimes however our customers need to be more pro-active, and they should participate in the REACH Consortium for their substance.
 
Some of the reasons to be pro-active in the registration process:
 
• The composition or the form of your substance is different from the industry standard.
 
• The uses of your substance are special and may not be covered by the consortium.
 
• The number of potential registrants is small and you want to be there when the cost are allocated.
 
• You have valuable data that could be used for the REACH registration dossier.

Our service in case of complex REACH registrations is tailored to the customer’s needs.
 
It may for example comprise:
 
• Comparison of the customer’s needs with consortium’s plans and progress.
 
• Representation of chemical manufacturers or importers in the REACH consortium.
 
• Legal advice on REACH consortium contracts.
 
• Advice on cost allocation in the REACH consortium.
 
• Production of complete registration dossiers for individual submissions or for a REACH consortium.
 
For more detail on this subject see our dedicated web page ‘Registration’.

Attaining REACH compliance in European companies is not always simple. The obligations depend on their REACH roles.
 
They may be producing articles, but purchase some of their raw materials outside the EU. If so, they are also importers of substances.
 
They may buy spare parts outside the EU; they import articles.
 
They may mix a few ingredients to make their own raw materials. If a chemical reaction occurs, they are a ‘manufacturer’ under REACH.
 
All sort of unexpected obligations may result.
 
Our service for REACH compliance in companies is tailored to the customer’s needs.

It may for example comprise:
 
• Analysis of the product portfolio, the raw material portfolio and the production processes.
 
• Advice on how to avoid certain REACH roles.
 
• Advice on providing REACH information down the supply chain.
 
• Advice on how to minimize compliance costs.
 
• Advice on how to set up a system to monitor and prove REACH compliance.

For articles Sitmae has developed a REACH Article Compliance method.
 
For more information on the subject visit our dedicated web page on Reach Article Compliance.

For more complex articles such as articles with an intended release or articles in a sophisticated container more REACH obligations may apply.
 
For the best approach please contact us for more information.

REACH is still under construction. New legal interpretations must be agreed, new Technical Guidance Documents are published and the REACH lists expand continuously.
 
In addition REACH is being reviewed (2011 and 2012). As a result it may even be revised (possibly in 2013). Industrial trade associations follow the work closely, and provide input on their members’ experience and wishes.

Mr. Paul Verspoor, Sitmae’s owner and founder, assists six different European trade associations as their REACH consultants. He is chairing the Chemi-Platform; a cooperation between some twenty international trade association of production industries. These are all end-users of chemicals and mostly SME’s (Small and Medium Sized Enterprises).