EU Chemicals & REACH

Steptoe & Johnson LLP has a long history of servicing and advising the chemicals industry in Europe with particular focus on pesticides, biocides (antimicrobials), hazardous substances regulations and the new REACH regime.

Chemicals & REACH
Our Brussels office has provided strategic analysis and representation for clients on REACH since the first stages of its legislative conception. We have been advising on the legal, regulatory and technical compliance obligations that it imposes since its adoption at the end of 2006.

Following the pre-registration deadline (1 December 2008) for phase-in substances, action that needs to be taken includes:

tracking other Pre-Registrants for each substance Pre-Registered, in particular identifying any SIEF formation facilitator, checking the total number of Pre-Registrants/identities, and keeping abreast of relevant information on status, use and related consortia;
preparing for "sameness" discussions about problematic substances, such as Substances of Unknown or Variable Composition, Complex reaction products or Biological Materials (UVCBs) and substances with multiple identifiers;
compiling an internal inventory of "own" data, including: confirming ownership documentation, assessing data quality, qualification for financial compensation and valuation;
checking the availability of "orphan" data and determining whether it should be contested;
determining all use patterns and availability of exposure data;
exploring the possibility of obtaining data waivers or establishing read across for specific end points;
making informed decisions on membership in existing consortia, with particular attention paid to pre-established conditions for membership and possible revisions to those conditions, including evaluating the need (or not) to transfer data to consortium as condition of membership; and
considering the value of assuming a leading role or "founder" status in a consortium in formation or where no consortium has yet been formed.

The sectors we represent include biocides, biotechnology, commodity chemicals, cosmetics, electronics, flavours, food, fragrances, medical devices, metals, pesticides, petrochemicals, polymers and textiles, toys and waste.

Our integrated REACH team, comprising both lawyers and technicians, enables us to provide our clients with an integrated "one stop shop" for efficient compliance with REACH.

Biocides & Pesticides
Our Brussels office has focused on the regulation of pesticides and biocides since the directives governing each area were issued. With respect to biocides, our firm has represented clients in different sectors of the biocidal products industry on issues including:

Strategy for obtaining marketing authorisation of biocidal products within the European Union;
Negotiation of consortia agreements;
Representation of clients on/in consortium meetings;
Data protection and compensation; and
Negotiations with the Commission and Member States’ competent authorities.

Steptoe also has a substantial practice representing plant protection product registrants. We support registrants before the Commission and Member States. Our lawyers also have defended registrations before the Court of Justice.

Our relationships with Commission and Member State officials help us to obtain prompt and accurate feedback on even the most difficult issues. In addition, our close working relationship with technical consultants enables us to ensure the effective and efficient preparation of dossiers, resulting in greater over-all efficiency and lower cost for clients.

Noteworthy

Steptoe Brussels Regulatory Environment Group Ranked as Leading Firm by Chambers Europe 2009

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Publications

Nanotechnology in the EU cosmetics regulation
October 2009, Household and Personal Care Today
REACH: Polymer-Specific Issues
August 7, 2009, Plastics News
REACH: Looking Beyond Pre-registration
August 2009, Chemical Engineering
REACH Authorization Process
July 17, 2009, Plastics News

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