EU Regulatory Update: Deadlines Loom Under the EU REACH Legislation
Client Alert | 1 min read | 03.13.13
The EU REACH legislation establishes an integrated system for the registration, evaluation, authorization and restriction of chemical substances. It requires all companies (including US-based companies) which manufacture in, or import chemical substances into, the EU in quantities of one ton or more per year to register them with the European Chemicals Agency in Helsinki, Finland.
Companies which have pre-registered "phase-in" substances (which include those listed in the European Inventory of Existing Commercial Chemical Substances) benefit from extended registration deadlines. A May 31, 2013 deadline for registration applies to substances produced or imported into the EU in volumes of between 100 and 1000 tons per year per manufacturer or importer.
The REACH legislation requires that the EU member states introduce penalties for non-compliance with its provisions. For example, in the UK, national enforcement provisions provide maximum penalties of an unlimited fine and/or up to two years' imprisonment following conviction on indictment for relevant infringements.
Downstream users of chemical substances should check to ensure that their suppliers have registered the relevant substances. Otherwise, they will be unable to use un-registered substances which will be banned after the deadline.
In order to obtain assistance for compliance with the EU REACH legislation or any other EU regulatory issues, please contact one of the professionals listed below.
Insights
Client Alert | 3 min read | 11.21.25
On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future.
Client Alert | 3 min read | 11.20.25
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