AUTOMOTIVEINDUSTRY GUIDELINE ON
VERSION 4.1
THE AUTOMOTIVE INDUSTRY GUIDELINE IS DEVELOPED BY:BACK TO
CONTENTSCONTENTS 3
Executive summary 4
Foreword: About this Guideline 7
Chapter 1: Introduction – REACH and the automotive industry 8
Chapter 2: Main definitions10
2.1 Glossary of terms10
2.2 Acronyms & Initialisms20
Chapter 3: Important dates and deadlines to remember 22
Chapter 4: REACH compliance – a step-by-step process 25
4.0 Flowchart navigator 26
4.1 Registration of substances/substances in mixtures used in industrial (including engineering) processes 27
4.2 REACH authorisation procedures 28
4.3 Registration of substances intended to be released from articles29
4.4 REACH notification of substances in articles 30
4.5 Use of the Only Representative 31
4.6 Obligations for importers 32
4.7 REACH restriction33
4.8 REACH Art. 33 communication 34
4.9 SDS obligations for DUs35
Chapter 5: Automotive sector advice 37
5.1 Roles in the supply chain 37
5.2 REACH scope and exemptions 38
5.3 Substance inventory 40
5.4 Imports of substances/mixtures/articles 43
5.5 Downstream user obligations according to REACH Title V 46
5.6 Safety data sheet and DU obligations (REACH compliance check) 49
5.7 CLP notification55
5.8 Registration of substances in articles 56
5.9 Notification of CL substances in articles58
5.10 Communication requirements for CL substances in articles 66
5.11 Authorisation procedure 70
5.12 Restriction procedure78
5.13 REACH and waste – impact on the automotive industry80
5.14 REACH enforcement 82
5.15 List of ECHA guidance documents 83
CONTENTS
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Chapter 6: 5-step REACH compliance schedule 84
List of annexes86 4
AIG ON REACH 4.0
least our customers. chain, at our facilities and dealerships and last but not human health and the environment along the supply finding substitutes for SVHCswhich better protect appreciates the efforts made inthe supply chain in be adequately managed. The automotive industry face upcoming duties with confidence that tasks can how to cope with inatimely REACH manner, it now can Whereas inthe past industry had been concerned about broad experience. automotive industry supply chain to benefit from this AIG would be helpful for vehicle manufacturers and the increasing CL, it was felt that another update of the in articles and communication due to the steadily authorisation of use, notification of CL substances and inthe light of upcoming processes which include of experience through the cooperation inthe Task Force registration deadlines. Having accumulated a wealth experience was gained from the first and second authorisation have been granted to industry. Also first sunset dates have passed and applications for ofCourt Justice. Furthermore under authorisation Also the term “article” has been redefined by the EU (hereinafter CL) and the Annex XIV Authorisation List. such as the continuous growth of the Candidate List processREACH has passed some important milestones Guideline (AIG) on Version REACH 3.1 inJune 2012 the Since the publication of the Automotive Industry Industry Guideline on (AIG). REACH and recommendations areoutlined inthis Automotive duplication and confusion. The TF-REACH approach harmonises the sector’s response to and REACH avoids schedule and external communication strategy which TheREACH). TF-REACH recommends acommon supply chain formed aTask Force on (TF- REACH major vehicle manufacturers and the automotive In preparation for representatives REACH, of allthe customers or subsidiaries doing business inthe EEA). doing business inthe (and EEA for businesses with with the Regulation REACH ismandatory for companies health or the environment may be restricted. Compliance substances which place unacceptable riskon human High Concern (SVHCs)may require authorisation and their suppliers. Under Substances REACH, of Very immediate and ongoing action from the OEMs and 1 June 2007 and affects all industries. It requires
The European Regulation REACHEXECUTIVE SUMMARY
1
came into force on
o o
1 ooo o o
Key messages Key
Authorisation (and Restriction) of Chemicals Regulation (EC) No 1907/2006 on Registration, Evaluation,
assess their obligations and next steps. stances/mixtures/articles they use. This willhelp to companies should have aninventory of the sub- Depending on the role(s) they perform inREACH, guidance on what to do next. the appropriate section of the AIG where you can find determine what your obligations are and direct you to side The EEA). flowcharts inChapter 4willhelp you porter of articles/mixtures/substances (from out engine, bumper manufactured inthe or EEA), anim- a producer of articles/complex objects (e.g. vehicle, es (e.g. magnesium) and mixtures (e.g. engine oil), sector performs: as a downstream user of substanc- imposes REACH different obligations for each role the
sions areset out inChapter 5.8. releases for the purposes of and REACH our conclu releases from articles areconsidered to be intended The sector has considered whether any substance ness risksposed by REACH. plan to ensure compliance and minimise the busi- representativeREACH and develop astrategic action Each actor inthe supply chain should appoint a dard awareness REACH letter inAnnex B). sures for safe use, etc. (see Chapter 5.5 and the stan chain needs to communicate data, uses, control mea- To fulfiltheir obligations, REACH the entire supply porter role (see Chapter 5.4). stead of each of their customers duplicating the im - whichEEA takes on the importer responsibilities, in suppliers appoint anOnly Representative (OR) inthe The AIG makes the recommendation that non-EEA stance to be registered up the supply chain. Downstream users (DUs) expect their uses of asub -
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o Chapter 6 of the AIG summarises the main obligations
and recommendations for the AI response to REACH
along with a timeline for each activity. These activi-
ties are broadly grouped into the 5-step REACH com-
pliance schedule (see Annex C) under the headings
of raising awareness, developing a substance inven-
tory, declaration of intent (three steps), SVHC and
risk management measures and uses.
o The Chapters 5 and 6 describe the different process-
es around supply chain communication, including
the SDS/Ext-SDS requirements with a focus on DU.
This chapter is followed by information about CLP and
the notification duties.
This Guideline is a living document which will be updated
in light of guidance and the practical experience gained
by TF-REACH members when tackling the different
REACH processes.
Disclaimer
This document contains guidance explaining the REACH obligations for the Automotive Industry and how to fulfil
them. It is offered in good faith and reflects the best knowledge of the global automotive industry experts and the
state of the art at the time of its publication. However, users are reminded that the text of the REACH Regulation is
the only authentic legal reference and that a binding interpretation of EU legislation is the exclusive competence
of the European Court of Justice. Therefore the information and guidance in this document are not legally binding.
The associations responsible for the publication of this document will not accept any liability regarding the
contents of this document or arising from its use.
The associations are committed without reservation to fair competition. As trade associations, their purpose
is to promote the interest of their members and to facilitate their respective aims and objectives only through
legitimate means and activities. In carrying out this role, the associations shall proceed with caution to ensure
against violation of the EU antitrust laws.
EXECUTIVE SUMMARY EXECUTIVE
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13 July 2022