REACH
EU regulation for chemicals registration, evaluation, authorisation, restriction
23 NYCRR 500
New York regulation for financial services cybersecurity.
Quick Verdict
REACH mandates chemical safety across EU supply chains for market access, while 23 NYCRR 500 enforces cybersecurity for NY financial entities. Companies adopt REACH to sell in Europe; Part 500 to avoid fines and protect operations.
REACH
Regulation (EC) No 1907/2006 on REACH
Key Features
- Shifts burden of proof to industry for hazard data
- Mandatory registration for substances over 1 tonne/year
- Authorisation regime for SVHCs to drive substitution
- EU-wide restrictions on unacceptable chemical risks
- Supply-chain SDS and Article 33 communication duties
23 NYCRR 500
23 NYCRR Part 500 Cybersecurity Regulation
Key Features
- Annual CISO/CEO dual-signature certification
- 72-hour cybersecurity incident notification
- Phishing-resistant MFA for high-risk access
- Comprehensive third-party service provider oversight
- Risk-based annual penetration testing requirements
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
REACH Details
What It Is
REACH (Regulation (EC) No 1907/2006) is a directly applicable EU regulation establishing a comprehensive framework for managing chemical risks across their lifecycle. Its primary purpose is to ensure a high level of protection for human health and the environment by requiring industry to identify, assess, and control chemical hazards. The core approach is industry-led responsibility, shifting the burden of proof from authorities to manufacturers and importers through data generation and submission.
Key Components
- Four pillars: Registration, Evaluation, Authorisation, and Restriction.
- Technical annexes (I-XVII) detailing data requirements, SDS rules, SVHC criteria, and lists like Annex XIV (Authorisation) and Annex XVII (Restrictions).
- Built on principles of precaution, substitution, and no-data-no-market.
- Compliance model relies on ECHA database submissions; no central certification but national enforcement with "effective, proportionate, dissuasive" penalties.
Why Organizations Use It
Legal obligation for EU market access; mitigates fines, product seizures, and market bans. Enables risk reduction, supply-chain transparency, innovation via safer alternatives, and ESG alignment. Builds stakeholder trust through SVHC communication (Article 33).
Implementation Overview
Phased approach: gap analysis, substance inventory, dossier preparation (IUCLID), SDS management, monitoring Annex updates. Applies to manufacturers/importers (>1 tpa), downstream users across sectors; global firms use Only Representatives. No formal certification; focuses on continuous dossier maintenance and audits.
23 NYCRR 500 Details
What It Is
23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a prescriptive state-level mandate for financial services entities. It establishes minimum risk-based cybersecurity requirements to protect nonpublic information (NPI) and ensure operational integrity, using a risk-assessment-centric approach with phased compliance timelines post-2023 amendments.
Key Components
- 14 core requirements including cybersecurity program, CISO governance, MFA, encryption, asset inventories, penetration testing, third-party oversight, and 72-hour incident reporting.
- Built on NIST CSF or equivalent frameworks; features annual CISO/CEO dual certification and five-year record retention.
- Class A companies (>$20M NY revenue, >2,000 employees or >$1B global) require enhanced controls like independent audits and EDR.
Why Organizations Use It
- Mandatory for NY-licensed financial entities to avoid multimillion-dollar fines (e.g., Robinhood $30M).
- Enhances resilience, reduces incident risk, builds stakeholder trust, and aligns with enterprise risk management.
Implementation Overview
- Phased roadmap: gap analysis, risk assessment, control deployment (MFA, PAM), vendor updates, testing.
- Applies to banks, insurers, mortgage firms in NY; involves governance, tech upgrades, evidence repositories.
Key Differences
| Aspect | REACH | 23 NYCRR 500 |
|---|---|---|
| Scope | Chemicals registration, evaluation, authorisation, restriction | Cybersecurity program, governance, incident response, controls |
| Industry | Chemicals, manufacturing, all EU supply chains | NY financial services, banks, insurers, licensees |
| Nature | Mandatory EU regulation with national enforcement | Mandatory NY state cybersecurity regulation |
| Testing | Dossier evaluation, substance evaluation by ECHA/MS | Annual penetration testing, vulnerability assessments |
| Penalties | National fines, effective/proportionate/dissuasive | Multi-million fines, consent orders, license actions |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about REACH and 23 NYCRR 500
REACH FAQ
23 NYCRR 500 FAQ
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