Exemptions?

No company is exempt from the requirements for chemical safety, but you could have exemptions from REACH and CLP when other legislation applies. 

Total exemptions 

  • Radioactive substances
  • Substances in temporary storage under customs supervision, provided they are not being transformed or processed in any way
  • Substances used in the interest of defence when (these are) covered by specific national exemptions
  • The transport of hazardous substances on their own or in mixtures
  • Non-isolated intermediates – these are substances that appear between two successive chemical reactions and that are not removed from the system, except for sampling

Waste, as defined in the EU's waste legislation, is exempt from REACH, but a product recovered from waste is not. REACH applies for any substance, mixture or article you recover from waste that meets the end of waste criteria. It is however sometimes possible to get an exemption for a recovered substance that has already been registered by someone else. 

Partial exemptions

Some groups of substances are exempt from specific requirements:

The registration and authorisation requirements do not  apply to substances used in:

  • Scientific research and development
  • Food and feedstuffs
  • Medicinal products

Registration is not required for substances:

  • That present minimum risk because of their basic properties (e.g. water, nitrogen) listed in Annex IV of REACH
  • Occurring in nature (e.g. minerals, ores and ore concentrates that are not chemically modified) where registration is deemed inappropriate or unnecessary. See Annex V of REACH
  • Already registered, then exported from and re-imported into the EEA, by an actor in the supply chain
  • Already registered and recovered through a waste recovery process

Active substances used in plant protection and biocidal products are considered as already having been registered.

ECHA's Guidance on Registration provides an overview of the total exemptions from REACH and those specific to registration.