Maintaining

Critical
Control:
Outsourcing
REACH Compliance

ACC Docket 44 January/February 2009

 on
By Catherine A. Muldo

ti ck in g. Th e period of RE ACH pre

-registra tion has now
k isred? What is your company’s compliance strategy? Ouicatsol regurculaingtion,
Theed. cArle yooucpre pa -sweeping chem
expir t and broad
including the EU’s lates RE ACH to provide
regulator y compliance, yo ur co mp an y. Enabling experts on
d decis ion for rization and
RE ACH, may be a soun lia nc e str ate gy wil l ensure proper autho
effec tive co mp instant access
your company with an s int err up tio n. Outsourcing provides
ing any bu sin es ule imposed
registration, while avoid rig oro us an d on -g oing compliance sched
d maintain the nce
to expertise to meet an urcing RE ACH complia
nte d reg ula tio n. An d, if done right, outso s in yo ur co m-
by this newly impleme substance
los ing co ntr ol ov er critical aspects of the co nfide ntial
ut sure of
can be achieved witho ct to RE AC H, and with minimal disclo
t are su bje
pany’s supply chain tha crets.
ary inform ati on, including trade se
and propriet

ACC Docket 45 January/February 2009

Understanding REACH od and final phase-in registration periods ranging
As defined by the European Chemical Agency from 3 to 11 years.4 For “non phase-in substanc-
(ECHA), “REACH is the Regulation for Registra- es” there is simply a registration period and no
tion, Evaluation, Authorization and Restriction of staggered deadlines established under REACH.
Chemicals.” (Regulation (EC) No 1907/2006). It Catherine A. In almost all cases, these substances must be
Muldoon is chief
is the world’s most ambitious law on public health legal officer with BDP registered before they can be manufactured or
International, Inc., a
and environmental protection. It became law on leading global logistics
imported into the EU. As of June 1, 2008, all non
June 1, 2007, and is designed to consolidate exist- provider. She man- phase-in substances must be registered if they are
ages all corporate legal
ing laws and regulations governing chemicals into matters globally. She to be manufactured or imported into the EU.5
a uniform legal code regulating both existing and earned her BA from The registration period exceeds 11 years for
The Johns Hopkins
new chemicals manufactured in and imported to University and JD from some 30,000 chemicals. No substance covered
the European Union. REACH places significant Seton Hall School of by the regulation can enter the EU without the
Law. Muldoon is vice
responsibilities on manufacturers and importers chair of Corporate proper registration and certification. The obliga-
to collect data and share information about the Counsel Forum of the tory registration dossier requires disclosure of
International Bar Asso-
substances used in their respective products and ciation and a member chemicals in your inventory and in preparations
of and speaker for ACC.
any risks posed by such substances to human She can be contacted at
or finished goods that you export, distribute or
health and the environment. cmuldoon@bdpnet.com. handle. The nature and volume of each chemi-
REACH applies to chemicals used in industry cal affects the final registration deadline, and
and in everyday life whether in their raw form, in therefore, it is critical that it is categorized
preparation of a substance, or as finished goods. Specifically, accurately. The process for calculating the volume of each
REACH requires EU-based chemical manufacturers and chemical is also critical and must be accurate, as volume
importers to “collect all available relevant information on relates to deadline.6 This option of outsourcing provides a
the intrinsic properties of a substance, regardless of ton- means to compliance, while avoiding EU sales interruption
nage manufactured or imported.”1 The intended result is a of REACH regulated products.
comprehensive flow of information concerning the risks of The REACH compliance process is complex: Its risks are
substances throughout the industry and to consumers. Reg- great, and the penalties for non-compliance are daunting.
istration of substances is affected through the submission of Manufacturers and importers are faced with extensive data
a dossier to ECHA which includes information on the sub- gathering and sharing requirements, as well as the possible
stance’s properties, use and safe management. Registration need for costly testing of chemicals to fill information gaps.
is applicable to any substance manufactured in or imported There is potential for divulgence of confidential data and dis-
to the EU in annual quantities of one ton or more per com- closure of trade secrets for the unschooled REACH navigator.
pany, unless there is an exemption.2 Manufacturers, import- It is critical that REACH compliance be handled deftly and
ers, distributors and downstream users all have obligations accurately in order to ensure that your company is compli-
under REACH. Companies wishing to import products ant. Failing to comply with the registration and authorization
to the EU must demonstrate REACH compliance, or their requirements jeopardizes that company’s place and business
products will not be permitted entry to any Member State in the EU market. Manufacturers and importers which fail to
market. This mandate is rigorous and compels companies to comply on time must cease the manufacture and importation
begin the compliance process for REACH without delay. until they comply with the strict REACH timeframes.
The obligations of REACH commence with the begin-
ning of the pre registration period. Pre registration ran Supply Chain Solution: Is Outsourcing REACH
from June 1, 2008, to December 1, 2008. Companies an Option for You?
which pre register chemicals enjoy the benefit of extended In the event that your company is unable (or unwill-
registration deadlines for those chemicals. The company ing) to perform REACH compliance internally, can
must then proceed through the full registration process for your company transfer to a third party the obligation
those chemicals that are to enter the EU market. Deadlines to comply with REACH? Can REACH obligations be
to complete registration for pre-registered chemicals are outsourced? Simply stated, only a natural or legal person
November 30, 2010; May 31, 2013; or May 31, 2018. The established in the EU can be a registrant. If your com-
staggered deadlines depend on “tonnage band and the pany is an exporter of chemicals to the EU and does not
hazardous properties of the substance.”3 have a subsidiary in the EU, the options for outsourcing
For “phase-in substances”—those that were already being are limited. Pursuant to REACH, foreign nationals to the
manufactured or imported into the EU before the enactment EU, with the intention to continue business within the
of REACH on June 1, 2007—there is a pre registration peri- EU market, cannot register their chemicals themselves.

ACC Docket 46 January/February 2009

There are three options for such an entity:
• Set up a subsidiary within the EU;
• Work through the importer in the EU; or
• Register through an Only Representative.
The first two options may have undesirable and unantici-
pated commercial consequences. Creating a subsidiary
entity can be costly and burdensome in terms of corporate
maintenance and management. Working with an importer
creates a complicated arrangement as confidential and
proprietary information will be released to a third party.
Any formula or component of a product will need to be
disclosed, risking trade secrets and exposing a company
to reverse engineering. Also, to the extent that it relies on
the EU market, the company business is vulnerable to the
filings of an entity with which it may have little connection
or loyalty. Control and ownership over the registration is
relinquished, making it difficult to alter future distribution
channels in the EU. In fact, if an exporter changes sup-
pliers, the non-EU manufacturer may lose access to the
European market. The Only Representative option provides
a mechanism for manufacturers located outside the EU to
participate in REACH pre-registration and registration. The
definition of an Only Representative for REACH purposes
is loose. It must both be a legal entity established in the EU
and have “sufficient background in the practical handling of
substances and the information related to them to be able to
fulfill the obligations of importers.”7 A critical advantage of
the Only Representative is that it is not required to reveal to
other participants in the data sharing process the identity of
the “non-Community manufacturer” being represented.8
Specific Outsourcing Advantages for REACH Compli-
ance Making the Only Representative Work for You
Certain companies do not have the capacity, or in the
instance of REACH, the corporate structure, to establish
an effective in-house compliance program. As indicated
by the above deadlines imposed under REACH, time is of
the essence. If you cannot move quickly to comply, the EU
market will be closed to you until you have registered all
substances that fall within the purview of REACH. Your
Only Representative is your adviser for a global REACH
strategy that works for your company and its particular
needs. Such a strategy should complement your internal
compliance department and program through REACH
transaction auditing, training and the development of ap-
propriate policies for present and future filings.
Selecting a Vendor: Expertise
Find the vendor best equipped to propel your business for-
ward. As this complex regulatory scheme is newly-developed,
it is not certain how REACH will be interpreted and enforced.
Thus, there is no substitute for knowledge or technical skill of
ACC Docket
Eight Benefits of Managing REACH
Compliance Internally
Managing REACH compliance internally may make
sense for your company. Some of the benefits include:
• Reducing exposure to liability by maintaining control
over the regulatory compliance.
• Increasing company awareness of key compliance
issues for REACH and other regulatory schemes
“across the board” in all departments.
• Maintaining progress on your timeline and having more
control over critical decisions.
• Another layer of protection for confidential or
proprietary material.
• Greater influence on the direction and content of SIEFs.
• Increased management stake in compliance.
• A more cost-efficient means to comply with the
complex regulatory scheme.
• Seamless project management—no new faces to work
with or new places to work at.
the regulation when choosing a vendor. Given what is at stake,
your Only Representative must be fluent in REACH and be
an effective organizer and communicator. Look for evidence
that the Only Representative will bring best practices to the
table. This entity should have long-standing experience in
EU regulations for chemical safety, chemistry and toxicology,
environmental risk management, legal issues and information
technology for seamless REACH implementation.
The technical expertise is only one aspect of what is
needed for your Only Representative to be effective. REACH
mandates that the registrant undertake onerous data gather-
ing and submission in order to meet the registration and
authorization requirements. As your registrant, the Only
Representative will be tasked with organizing your compa-
ny’s data. As owner of that data, you should require that any
information compiled for REACH compliance be transparent
to you such that you are aware of the status of filings, infor-
mation requests, decisions made and actions taken. Further,
the information should be easily traceable so that you can
track results, which offers your company ultimate control.
When your involvement or communication is required, you
can respond within the critical time.
Finally, your Only Representative should possess excel-
lent communication skills to advocate on your behalf. As
the Only Representative is the registrant, that entity/per-
son is the face of your company’s compliance with REACH
to ECHA and the Member State’s governmental bodies. In
order to be effective, the Only Representative must present
your data in a timely and accurate fashion. Further, your
Only Representative must hold his own when dealing with
48 January/February 2009
non-governmental bodies as well. For example, the Only
Representative may need to be communicating with other
registrants in a Substance Information Exchange Forum
(SIEF) in the likely event that you are required to consoli-
date information. In addition, you might require that the
Only Representative negotiate on your behalf if you need
to present cost sharing test work or to value data held by
the supplier or importers with whom they are working.
Cost
Regulatory compliance always comes with a price tag,
and REACH is no exception. Ideally, this cost is managed
efficiently so that the benefit is realized in a manner that is
commercially reasonable. What should REACH compliance
cost? If you are insourcing, you will need the appropriate cor-
porate structure in place to satisfy the logistics of REACH in
addition to ensuring that your team is up to the technical task,
which may require personnel hiring/changes and a significant
training investment. If you do not have a subsidiary in the
EU, REACH requires setting up a company, obligating you to
meet all local Member State requirements and its attendant
banking, labor and tax consequences. Further, to manage the
on-going REACH tasks in compliance activities, the corporate
structure must maintain corporate standing and governance.
Although the adage “never outsource your core value”
may be applicable, there is little room for error with REACH.
The cost of outsourcing may be appealing in light of the
various obstacles to compliance for an exporter. How critical
is the EU market to your business? Can you afford to miss
a deadline? It is essential that you look first at your business
objectives and the type of services at which your corpora-
tion excels. Does REACH fit into your compliance program
easily? Dealing with REACH effectively requires more than
just allocating costs. An effective cost analysis should begin
with an honest review of your company’s existing structure
and your team’s technical knowledge of the regulation. That
piece is then weighed against the cost of securing a qualified
vendor to handle outsourced services under REACH. This
will likely provide a professional advantage to your company,
as your resources will not be diverted from efforts integral to
your company’s mission in order to satisfy REACH. A com-
pany can rely on experts in regulatory compliance and shift
the responsibility of organizing and communicating informa-
tion among the authorities, the industry, and consumers.
Confidentiality/Control
Pursuant to REACH, the registrant owns the registra-
tion. If that registrant is your importer or distributer, that
entity, rather than you, owns the registration of your data of
substances and is responsible for communicating to ECHA.
In order to be effective, this registrant will require you to
disclose the detailed composition of your product. This is a
ACC Docket
tremendous amount of responsibility and authority to give
over to your registrant and can lead to grave consequences.
For example, because you are dependent on a single reg-
istrant, be it your importer or distributor, if you intend to
change your strategy and terminate or add distributors or
importers, you are vulnerable to the registrant, who has
retained your registration and can be an obstacle to the entry
of your products to the EU. As a consequence of working
with an importer/distributor as registrant, you will need to
make a significant investment in such a relationship.
To avoid what may be a hindrance to your ability to control
your product’s entry to the EU, REACH carves out the “Only
Representative.” The “non-EU manufacturer” must alert all
EU importers in the same supply chain that an Only Repre-
sentative has been appointed to fulfill the registration require-
ments under REACH. This absolves the importer from those
same registration requirements and insulates the manufacturer
from disclosing proprietary information to the supply chain.
The Only Representative provision gives you the choice
of whom you will inform of your company’s confidential
business information including the substances in your
inventory, preparation and articles. If there is any concern
over reverse engineering, the practice of using an Only
Representative under strict guidelines of confidentiality
would quell that concern. The Only Representative is ap-
pointed by a “non-EU manufacturer” as essentially a proxy
to handle the registration and data sharing requirements.
Appoint Your Only Representative
You have chosen your vendor, and the next step is to
appoint that vendor to be your Only Representative to pre-
register, register and if necessary procure authorization for
your substances with the goal of your continued business in
the EU. The Only Representative can only be appointed by
the manufacturer, formulator or producer and by this, the
regulation implies that traders or export agents cannot make
such an appointment. It is certainly best if the appointment
is made as far up the supply line as possible as these organi-
zations will have a better understanding of the substance.
This arrangement should be formalized to avoid confu-
sion as to the roles and responsibilities of your company and
the Only Representative. Although how an Only Representa-
tive is appointed is not explicitly defined in the regulation,
best practices would suggest that the agreement between the
relevant parties be in writing. Clearly, the Only Representa-
tive must be appointed by the non-EU entity, and the role
must be predicated upon agreement by the importer. The
recommended practice is to get a letter from your company
naming its Only Representative. This is your only protection
as the letter should secure the agreement of the participants
in your supply chain relating to the roles and responsibilities
associated with REACH compliance.
50 January/February 2009
Plan for the Outsourcing Transition
You have determined that outsourcing is your best
option for compliance, and you have the commitment of
your Only Representative. The next step is to plan for an
outsourcing transition of REACH compliance. Transition
is the number one management problem in an outsourcing
program. Do you have the internal building blocks for suc-
cess? In order to maximize the relationship, make sure you
thoroughly understand and plan for each activity that will
be a component of the transition.
Generally, the success of a REACH outsourcing proj-
ect depends greatly on your company’s commitment to
compliance and the ability of your management team to
maintain control of the outsourcing relationship. To that
end, the focus should be on establishing the relationship
and maximizing its benefits. REACH compliance must
be a directive from the highest authority. The message
that the Board Room “owns” the project is critical to its
success, since it establishes that the company is invested
from top to bottom in ensuring that the outsourcing
relationship is working.
It is essential that your company build an effective in-
ternal project management team, which may require some
organization redesign. This team must be empowered with
all oversight and decision-making authority on every aspect
of the REACH project, including scope of work, incentives,
penalties and risk mitigation strategies. The outsourced
party is the Only Representative, the legally responsible
person for the communication and registration of the speci-
fied substance. Operationally, your team can take on as
much work as you desire behind the scenes. For example,
your own technical specialists may organize the testing and
prepare information for the SIEF, but the final submission
is done by the Only Representative.
Negotiating the Contract
As parties will be bound by its legacy, a healthy out-
sourcing relationship requires a good contract. Think of
the relationship as a partnership because REACH com-
pliance is not an event but a process, which may change
depending on your company’s supply and manufacturing
goals and opportunities. The contractor should be appoint-
ed as the Only Representative to avoid any confusion as
to its role with respect to REACH administration require-
ments. This will also assure that you are receiving quality
services and appropriate accountability. A good REACH
outsourcing contract will spell out all expectations, terms
and responsibilities in the contract. Although the tempta-
tion is to negotiate a win on every term, it is important
that the contract be reasonable. It may not benefit you to
push the Only Representative to accept reduced pricing or
unrealistic terms and conditions.
ACC Docket
Scope of Work
You have negotiated the “how” through the appointment
of the Only Representative, now pin down the obligations
and the “what” of the contract, through a very detailed
scope of work. To ensure a meeting of the minds, the
scope of work is critical. Flexibility should be built in, but
a clear understanding of objectives and duties is required
for success. Specifically, the type of services that may be
outsourced to the Only Representative in connection with
REACH compliance could be stated as follows:
• Evaluate risks and exposure associated with REACH;
• Maintain all communications and negotiations with ECHA
and all relevant Member State governmental bodies;
• Identify and communicate with all importers, distribu-
tors and downstream users;
• Prepare and submit the technical registration dossier;
• Make the filings, register the chemicals, and pay all
attendant fees;
• Coordinate data exchange and testing strategies with
SIEF group and Consortium members;
• Create and submit safety data sheets and chemical
safety reports; and
• Audit and train where needed;
• Prepare notification of substances of very high concern;
• Address classification and labeling; and
• Perform any other obligations resulting from authoriza-
tions or restrictions.
The Only Representative must meet all applicable
regulatory standards during the contract term. To avoid
confusion, specify the regulations and statutes at issue and
how the Only Representative will comply. Also, the Only
Representative must comply completely with all on-going
and new obligations of REACH. Clearly, it will not be pos-
sible to define all of the requirements and situations that
may arise during this complex engagement. The only way
to deal with the unexpected is to have a real partner, and
to assign appropriate value to building a strong relation-
ship with the Only Representative. This requires manage-
ment time and effort. Make sure your team has the right
personalities to achieve a successful partnership.
Pricing Terms
In seeking to outsource REACH compliance, there
are some general pricing terms to consider in the con-
tract negotiations to ensure that your company receives
the full benefit of the relationship at a competitive rate.
These are a few terms that address such issues:
• Cost Plus Pricing—This method of pricing is arrived at
when the Only Representative discloses its costs and
adds a percentage in for a profit.
• Fair Pricing Clause —This sets forth that you can be
allowed to compare your outsourcing cost with the
51 January/February 2009
 averages on the open market and negotiate for price re-
ductions if your Only Representative’s costs are higher.
• Most Favored Nation—This stipulates that charges must be
at least as low as the Only Representative’s lowest charges
to other companies for substantially similar services.
Other Key Outsourcing Contract Terms
Ultimately, your objective is compliance with a newly-
passed regulation, and this must be written into your
Registration Deadlines
When a company pre registers it benefits from extended
deadlines. The deadline depends on tonnage band and
hazardous properties of the substance as follows:
A. November 30, 2010:
Phase-in substances that were manufactured or
imported into the EU at least once after June 1, 2007, in
quantities of 1,000 tons or more per year per manufacturer
or importer.
This deadline also applies to other substances which
are classified in accordance with Directive 67/548/EEC
and R50 /53 and are manufactured or imported into the EU
at least once after June 1, 2007, in quantities of 1 ton or
more per year per manufacturer or importer or 100 tons or
more per year per manufacturer or importer, depending on
the substance and the category.
Timeline: REACH Registration
>1000 tons/yr
P
CMR 1 +2 (>1 ton/yr Registration
R50/53 (>100 tons/yr)
>100 tons/yr P Registration
>1 ton/yr P Registration
Data Sharing
Authorization
Not yet on the market Non-Phase-in Substance Registration
June 1, 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
ACC Docket
contract. There are methods to incorporate incentives
and accountability in these uncharted waters of REACH.
First, to ensure that you have the right talent on the team
of your Only Representative, it may be in your best inter-
est to structure the contract to address project staffing.
The contract should specify that you get the best people
working on your account and as much personnel conti-
nuity as possible. You are seeking a guaranty of perfor-
mance. To that end, the parties can develop incentives and
B. May 31, 2013:
Phase-in substances that were manufactured or imported
into the EU at least once after June 1, 2007, in quantities of
100 tons or more per year per manufacturer or importer.
C. May 31, 2018:
Phase-in substances that were manufactured or imported
into the EU at least once after June 1, 2007, in quantities of 1
tons or more per year per manufacturer or importer.
The highest tonnage “per year” manufactured or imported
after June 1, 2007, determines the deadline for registration.
Substances not pre-registered but which are imported for the
first time into the EU after December 1, 2008, may benefit from
the above staggered deadlines if the information requested
for pre-registration is provided within six months of the first
import into the EU and no later than 12 months before the
relevant registration deadline.
End of
phase-in
52 January/February 2009
penalties to ensure that a high quality team is put (and
kept) on your account and that they are contracted to
perform. Where there is a risk to meeting the milestones
of REACH, you mitigate that risk by identifying it and
deploying a good strategy and process to manage it. The
parties may agree to a continuous improvement provision
stating that the Only Representative will improve its ser-
vices levels yearly while meeting the ongoing obligations
of REACH. This can be a clear incentive to both parties
to make efficiency improvements if your contract grants
a profit split between the parties in the event that such
improvements are quantifiable. In addition, clearly defined
penalties, such as a liquidated damages clause in the con-
tract, may be critical to success. If crafted well, the risk of
payment to recoup losses for inadequate performance will
motivate your Only Representative to ensure compliance
with the REACH milestones.
Finally, confidentiality must be underscored in this
context. You will need to disclose all chemicals within
your substances to your Only Representative in order for
those substances to enter the EU market. Otherwise, your
Only Representative cannot comply. You should mandate
by contract that your Only Representative to maintain the
information with the strictest of confidence and use that
information for the sole purpose of REACH compliance.
Any other disclosure must be strictly proscribed. Other-
wise one of the key reasons for using the Only Representa-
tive, maintaining control of your information, is defeated.
Trade secrets, proprietary, or other highly sensitive
information that provides a competitive advantage must
be kept confidential indefinitely.
Since the parties are in control of the terms of the
engagement, there is no limit to creativity when negotiat-
ACC Extras on… Maintaining
Critical Control
Program Materials
• The ABCs of Environmental Due Diligence (2001). Articles
with caselaw, SEC rules, model site access, and confiden-
tiality agreements, sample webpage and web-enhanced
due diligence chart. www.acc.com/vl/public/programmate-
rial/loader.cfm?csmodule=security/getfile&pageid=20684
• Best Practices in Tracking Environmental Law Worldwide
(2004). www.acc.com/vl/public/programmaterial/loader.
cfm?csmodule=security/getfile&pageid=20417
ACC has more material on this subject on our website. Visit
www.acc.com where you can browse our resources by prac-
tice area or use our search to find documents by keyword.
ACC Docket
ing and structuring the contract. In short, a good contract
will spell out all the requirements of REACH compliance
including a clear statement of expectations and respon-
sibilities, the scope of the work and the fees, the open
exchange of information and status reports, a process for
changing the scope of work (in the event something un-
foreseen arises that requires additional attention), person-
nel requisites for performance, incentives and penalties.
This is new territory. Don’t be afraid to make demands or
audits in the contract to maintain a check and control on
performance of your Only Representative.
Maintaining Your Competitive Edge While
Ensuring Compliance
The pre-registration period is over. If the EU market
is critical to your business, you need a solution to ensure
REACH compliance. In your company’s cost benefit
analysis, management must consider the value of the EU
market and how the company expects to remain competi-
tive while ensuring compliance. What factors will drive
your decision whether to outsource REACH compliance?
A successful outsourcing relationship for REACH
compliance is ideal to maintain a company’s competi-
tive edge while allowing trusted experts to handle the
arduous, complex and ongoing compliance schedule.
It is clear that with the right outsourcing assistance, a
company will maintain ownership of the registration
and control over the process of what, when and how its
information is filed under REACH.
Have a comment on this article? Email editorinchief@acc.com.
NOTES
1. ECHA, “Guidance on data sharing,” sec. 5.2, (Sept. 2007)
(visited June 24, 2008) http://reach.jrc.it/docs/guidance_
document/data_sharing_en.pdf.
2. ECHA, “Pre-register to benefit from extended deadlines” (visited
June 24, 2008) www.echa.europa.eu/pre-registration_en.asp.
3. ECHA, “Pre-register to benefit from extended deadlines,” (visited
June 24, 2008) www.echa.europa.eu/pre-registration_en.asp.
4. ECHA, “Guidance on Registration,” sec. 1.7.1.1 (May 2008)
(visited June 24, 2008).
5. ECHA, “Guidance on Registration,” sec. 1.7.1.2 (May 2008)
(visited June 24, 2008) www.reach.jrc.it/docs/guidance_document
/registration_en.pdf.
6. ECHA, “Guidance on Registration,” sec. 1.7.2 (May 2008) (vis-
ited June 24, 2008) www.reach.jrc.it/docs/guidance_document/
registration_en.pdf.
7. ECHA, “Guidance on Registration,” sec. 1.5.3.4 (May 2008)
(visited June 24, 2008).
8. ECHA, “Guidance on Registration,” sec. 1.5.3.4 (May 2008)
(visited June 24, 2008) www.reach.jrc.it/docs/guidance_document/
registration_en.pdf.
54 January/February 2009