Overview

Product stewardship – a product centred approach to environmental protection – affects all UK and multinational manufacturers, suppliers, downstream users and retailers. We advise on all aspects of UK and EU product stewardship regimes including compliance, enforcement and disputes. Our clients range from governments and industry trade associations to EU projects and UK and multinational businesses.

We provide the support that organisations need to understand their obligations, to work effectively with their supply chains and regulators, to have robust contracts and document management procedures, and to resolve problems and address enforcement action.

Our experience and reputation in this area has developed over many years. For example, one of our team was involved in the negotiation of the REACH Regulation over two and a half years for the metals and mining industry and aerospace clients.

Areas of focus

Our REACH, chemicals regulation and product stewardship expertise includes the following areas:

  • REACH Regulation.
  • Classification, Labelling and Packaging 'CLP' Regulation.
  • Biocidal Products Regulation 'BPR'.
  • Restriction of Hazardous Substances in Electrical and Electronic Equipment 'RoHS' regime.
  • Waste Electrical and Electronic Equipment 'WEEE' regime.
  • EU marking, packaging and labelling requirements for products.
  • Cosmetics Regulation.
  • Food contact materials.
  • Control of pesticides.
  • Emerging supply chain issues including Conflict Minerals, Modern Slavery and Human Rights issues.
Experience

Challenging decisions of the European Chemicals Agency through appeals to the ECHA Board of Appeal in Helsinki.

Advising the European Commission (DG ENV), as part of a consortium with Wood plc, on the regulation of intentionally-added micro-plastics in products.

Representing a European petrochemicals company on an investigation by the Dutch police into products supplied on the European market.

Advising an international chemicals consortium on one of the first REACH Data Sharing disputes before the European Chemicals Agency 'ECHA'.

Advising a waste recovery firm on REACH obligations and restrictions relevant to feedstocks, products and customers.

Defending the UK distribution arm of a US manufacturer during one of the first regulatory investigations under the RoHS regime for non-compliant machinery on the EU market.

Advising a public authority on a business-critical use of a chemical and the application of the Biocidal Products Regulation and REACH to business continuity.

Advising a UK chemicals manufacturer on compliance issues involving REACH, CLP, Control of Pesticides Regulations and Biocidal Products Regulation.

Advising a US medical diagnostics company on REACH, CLP, RoHS, WEEE and enforcement.

Providing advice to aerospace primes on issues of REACH Authorisation and Candidate List, and membership of the A/D/S trade association Environment and Hazmat committees.

Advising on REACH data sharing agreements with companies from the USA, Japan, China and India.

Providing REACH advice to several multinationals on corporate responses as downstream users, manufacturers and importers and on registration and authorisation issues involving substances of very high concern (SVHC).

Advising a rubber manufacturer on issues of SVHCs and phthalates in products and articles.

Advising several multinationals in a range of sectors on business risk issues arising from the use of SVHCs, supply chain management and candidate list issues.

Advising a nanomaterials producer in the USA on the regulation of nanomaterials under REACH and nanomaterials regulation training workshop for industry.

Drafting documentation on Consortium Agreements, Only Representative Agreements, and Third Party Representative Agreements and advice on data sharing and cost allocation issues, and transfer of responsibilities to new Only Representative under REACH.

Meet the team
Simon-Tilling--250px x 250px 72dpi - web

Simon Tilling Partner

  • Environment
  • REACH, Chemicals and Product Stewardship
  • Energy, Power and Utilities
Michael Barlow

Michael Barlow Partner

  • Environment
  • Energy, Power and Utilities
  • Water