MOD Registration, Evaluation and Authorisation of Chemicals (REACH) REGULATION 1907/2006
Defence industry information: Application for a defence exemption from the requirement to submit information on chemical substances to the European Chemicals Agency under the REACH Regulations.
This website references four MoD REACH documents:
(i) REACH Guidelines for the Ministry of Defence - Report No. A.BMT.115.001
(ii) The REACH Process Guidance Document Report No. BMT.125.002
(iii) Defence Exemption Application Form and Guidance
(iv) An Article published in the Industry Association Publications detailing the MODs approach and overarching policy on the
REACH regulation.
The term Integrated Project Team (IPT), used in all MOD REACH documents, equates equally to all individuals, teams, business units and sections that procure substances, preparations and articles within the MOD.
The “REACH Guidelines” provide general information on the REACH legislation. The “REACH Process” document guides the user through the internal and external processes required to comply with REACH requirements and ensures that Defence Industry Partners, manufactures and suppliers are aware of the processes required to enact a REACH Exemption for Defence. The defence exemption is detailed in sections 2 and 3 of the process document. Please note that the processes described, for after, the exemption application and REACH pre-registration phases are still under construction and more detailed information will be published in due course.
Although it is the responsibility of all Defence Industry Partners to carry out registration of their substances under REACH, there is also the provision to enact a Defence Exemption from the requirement to submit MOD specific information to the European Chemicals Agency (ECHA) in the interests of defence. It should be noted, however, that the MOD policy on exemptions requires that an equivalent REACH process be carried out internally, that meets the requirements of the legislation.
Exemption applications should be initiated through the MOD IPTs or equivalent, with assistance from their defence industry partners, to ensure that any contracts are evaluated, and any substances assessed to determine if an exemption is justified. However, to aid the process, the application form has been made available to the defence industry. Applications submitted through procurement teams will be scrutinised by an internal DE&S committee.
In order to ensure that all Defence Exemption applications are submitted on time, please ensure that you contact your MoD IPT (or equivalent) partners to identify where Exemptions will be necessary. IPTs within the MoD have been briefed regarding REACH and the MoD, and will work with their Defence Partners to achieve this new legislative requirement.
The first deadlines for REACH are as follows:
• 31st August for Defence Exemption Applications submissions to the DE&S committee
• 1st December for REACH pre-registration
All Defence Exemptions should initially be sent to your partner IPT for review, they will then submit them to DE&S before the above deadline.
To ensure these time-scales can be met, all applications need to be submitted through the IPT (or equivalent) by 15th Aug 08. Application forms are also available via the MOD IPTs. Guidance on completing the application form is attached to the application form.
Where UK defence industries, without a MOD customer focal point; have a requirement for a defence exemption, they should contact shaun.ellis166@mod.uk to discuss their requirements.
Defence Industry Partners are urged to contact their suppliers to ensure that they are aware of REACH and have implemented plans to register of all the products they provide to your company. This will highlight where alternative suppliers, or products, need to be sourced after the REACH registration deadlines.
Date: 4 Jun 08