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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.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....