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EXPERTISE · AUTHORISATION
Authorisation
The REACH regime for substances that cannot be used at all after a set date unless specifically authorised — what it means, when it applies, and how to get an application right.
WHAT AUTHORISATION IS
Permission to keep using a substance the regulation wants phased out.
Authorisation is the REACH mechanism for substances identified as of very high concern and listed on Annex XIV — the Authorisation List. Once a substance is listed, it cannot be placed on the market or used after its sunset date unless a specific authorisation has been granted for that use, or the use is otherwise exempted.
Two dates matter for every listed substance: the Latest Application Date, by which a complete application must be submitted to keep using the substance while it is assessed, and the Sunset Date, after which use is prohibited unless authorisation has already been granted — or applied for in time, in which case use can continue while the application is decided.
✓Screening substances and uses against the current Annex XIV Authorisation List
✓Tracking Latest Application Dates and Sunset Dates for substances you rely on
✓Assessing whether your specific use actually needs an authorisation
✓Building the case for continued use, or planning substitution in good time
WHAT AN APPLICATION REQUIRES
Three documents, one defensible case.
A REACH authorisation application is built around three core technical elements: a Chemical Safety Report (CSR) covering the risks the use presents and the controls in place to manage them, an Analysis of Alternatives, showing whether a suitable alternative substance or technology exists and, if not, why not, and — for most applications — a Socio-Economic Analysis (SEA), setting out the costs and benefits of continued use against the costs and benefits of stopping or substituting.
Each of these has to be built from real operational and technical data, not template answers, because the committees that review them test for substance and internal consistency, not just presence. Weak evidence in any one of the three routinely leads to a poor opinion or a rejected application.
✓Chemical Safety Report covering exposure, risk and control measures
✓Analysis of Alternatives assessing technical and economic feasibility of substitutes
✓Socio-Economic Analysis where continued use is being justified
✓Evidence built from real process, exposure and supply chain data
COMPILING THE EVIDENCE
Turning scattered data into a submission that holds up.
The hardest part of an authorisation application is rarely knowing what documents are needed — it is pulling together the exposure data, process information, alternative substance research and cost data from across engineering, procurement, EHS and finance functions, in a form that is consistent and defensible under review.
We help coordinate that effort: identifying what evidence already exists, what needs generating, and pulling it into the Chemical Safety Report, Analysis of Alternatives and Socio-Economic Analysis in the structure and depth reviewers expect, so the application reflects one coherent position rather than several disconnected inputs.
✓Identifying what evidence already exists and where the gaps are
✓Coordinating input from engineering, procurement, EHS and finance
✓Structuring evidence to the depth reviewers expect
✓One coherent, defensible application rather than disconnected inputs
APPLYING VIA HSE OR ECHA
Coordinating the application — and the supply chain around it.
Since Brexit, UK REACH authorisation applications go to the HSE, while EU REACH applications go to ECHA — two separate processes, sometimes for the same substance and use, each with its own timeline and evidentiary expectations. Many applications are also joint submissions, made by several companies in a consortium sharing the cost and evidence burden of an application covering the same use.
We help you decide whether to apply alone or as part of a consortium, coordinate input where multiple applicants or supply chain partners are involved, and manage the practical differences between a UK and an EU submission so the same underlying evidence supports both processes rather than being built twice.
✓Managing separate UK (HSE) and EU (ECHA) application processes
✓Coordinating joint applications and consortia with other applicants
✓Working with supply chain partners who share the same use
✓Aligning evidence so it supports both UK and EU submissions
DEFENCE EXEMPTIONS
Where defence use follows a different route.
REACH includes an exemption for substances used exclusively for military purposes, and UK defence policy — including JSP 418 Leaflet 5 — sets out how that exemption should be considered and applied within MOD programmes. Relying on the exemption is not automatic: it needs a documented case that the use genuinely falls within its scope, and that case has to be revisited whenever a material, process or programme changes.
We help defence organisations and their suppliers work through whether an exemption genuinely applies, build the record to support that position, and — where it does not — run the standard authorisation process alongside the relevant defence standards and policy, rather than treating the two as separate problems.
✓Assessing whether a defence exemption genuinely applies to a specific use
✓Building and maintaining the record that supports an exemption position
✓Running authorisation and defence policy compliance (e.g. JSP 418 Leaflet 5) together
✓Revisiting the exemption position as materials, processes or programmes change
GETTING IT WRONG, AND THE CLOCK
Authorisation is time-bound, even when granted.
An authorisation that is refused, or a use that is found not to be covered by one, generally means the substance simply cannot be used after the sunset date — a supply chain and production risk that is difficult to unwind quickly once it lands. But even a successful authorisation is not a permanent answer: it is granted for a fixed review period, and every authorisation carries an ongoing obligation to keep looking for a suitable alternative.
That means the work does not stop once an authorisation is granted. We help organisations treat the review period as a working deadline — tracking progress on substitution, keeping the Analysis of Alternatives current, and preparing the review or reapplication in good time, so the authorisation does not lapse with no alternative in place and no further application ready to go. Letting a review lapse is exactly the kind of gap that leads to the risks of non-compliance we set out separately.
✓Understanding the consequences of an application being refused or misjudged
✓Treating the authorisation review period as a working deadline, not a settled outcome
✓Keeping substitution efforts and the Analysis of Alternatives current
✓Preparing renewal or reapplication in good time, before the authorisation lapses
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