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REACH - The New European Chemical Legislation


Registration, Evaluation, Authorisation and Restriction of CHemicals



What is REACH?

The REACH-Regulation EU No. 1907/2006 is in force since June 1st, 2007 and leads to a fundamental reformation of the present European Chemical legislation.

Both present systems, Registration of New Notified Substances and Risk Assessment for Existing Substances will be replaced by the new chemical legislation REACH which covers all substances.

REACH will necessitate the registration of around 30.000 chemical substances in the EU over a period of 11 years.

In the future, REACH registration will be considered a precondition for manufacturing, placing on the market and using all chemicals within the European Union (No data, no market).

Two of the major goals of REACH are to improve the protection of human health and of the environment. This is in line with the principles and goals of our SHE-policy (Safety, Health and Environment). Health and environmental protection, occupational and plant safety as well as quality assurance are vital components of our company policy. In order to meet these requirements, CHEMETALL has established an expert group.

REACH will not only have a drastic impact on chemical companies but it will also affect nearly all industries within the European Union, i.e. manufacturing, trade and service industries.

The REACH legislation compels all companies to register all substances manufactured, imported and placed on the market at a rate exceeding 1 ton per year with the European Chemical Agency (EChA). Exemptions for natural substances, polymers, articles etc. have been included in the regulation. This means that there is no obligation to register all substances produced or sold by CHEMETALL. Preparations generally do not have to be registered.

It will be necessary for the registration not only to collect data on the properties of substances but also to communicate their identified uses and to describe conditions for their safe usage as well as measures for risk minimization.

In contrast to present EU chemical legislation, REACH requires companies to take full responsibility for the description of the safe use of substances manufactured, imported and placed on the market. Therefore, it is important to specify all applications of our products used at our costumers and, if necessary, at your customers, too.

REACH registration also requires detailed information on exposure. Possible risks of the chemical substances and their breakdown products through their exposure to man and the environment have to be taken into consideration along all stages of the supply chain and over the complete life cycle of such substances.

Therefore, extensive communication and close cooperation between all links of the chain, from the manufacturer or importer to the downstream user, are absolutely vital for the implementation of REACH.

Principal procedure

CHEMETALL intends to pre-register all substances it produces within and imports into the EU. Registration should be completed within the transition period defined in the regulation.

CHEMETALL intends to retain its present range of products. We do not plan to reduce the number of our products due to REACH requirements.

CHEMETALL aims to obtain authorisation – if required - for all relevant uses which are technically required. This will include close co-operation with our customers.

CHEMETALL will also co-operate closely with its suppliers in order to ensure the continuity of supply of preliminary products and raw materials.

Material Safety Data Shee

In the future, an extended safety data sheet (MSDS) will be used as a communication tool in this process. In addition to all identified uses, the extended safety data sheet will contain conditions for handling and measures for risk management necessary to successfully guarantee the safe use of these substances.
As of 1 June 2007 safety data sheets must be compiled according to REACH specifications. Due to the multitude of MSDS's to be compiled short-term, European authorities have granted a transition period, which means that only some of CHEMETALL’s MSDS's have been changed so far. When material safety data sheets have to be updated, these changes must comply with the formal REACH requirements. Updated MSDS's will be issued depending upon the availability of new data.

Pre-registration

CHEMETALL has already compiled an inventory of all substances self-produced and/or imported which have to be pre-registered as of 1 June 2008. This pre-registration process entitles CHEMETALL to use the transition periods stipulated in the REACH regulation (30-November-2010, 31-May-2013, 31-May-2018).

Only in exceptional cases CHEMETALL will ask its EU-located suppliers whether their substances have been pre-registered or not. It is our understanding that it is in the best interests of our suppliers to undergo pre-registration of their self-produced or imported products. As soon as the list of pre-registered substances is published by the European Chemicals Agency (ECHA) in December 2008, CHEMETALL will check whether its suppliers have pre-registered the substances delivered to us. If necessary, missing substances will be pre-registered by CHEMETALL using the late pre-registration option.

Classification & Labelling Inventory

CHEMETALL has thoroughly examined its total range of products. Substances have been identified which have to be included into the Classification & Labelling Inventory as of 1-December-2010. CHEMETALL is in a position to meet notification requirements.

SIEF's/ Consortia

After the expiration of the pre-registration deadline (starting 2-December-2008) all producers and importers as well as data owners of the same substance are considered to be members of a so-called SIEF (Substance Information Exchange Forum). It is the goal of the REACH regulation that members of a SIEF share available substance data.

CHEMETALL has already contacted possible consortium partners manufacturing the same substances in order to check the establishment of a consortium.

Moreover, CHEMETALL has also had preliminary discussions with institutes as to possible testing.

Registration

By 30-November-2010, substances have to be registered which are produced and/or imported:

In quantities ≥ 1 000 t/year, or
In quantities ≥ 100 t/year if they are classified as R 50/53 or
In quantities ≥ 1 t/year if they contain CMR (carcinogenic, mutagenic, reprotoxic) properties of category 1 or 2.

By 31-May-2013, registration is obligatory for all substances produced or imported in quantities ≥ 100 t/year.

By 31-May-2018, registration is obligatory for all substances produced or imported in quantities ≥ 1 t/year.

Safe Use during Life Cycle (CSA/CSR)

CHEMETALL will execute and establish chemical safety assessments and reports (CSA/CSR) if required. Uses will be identified and recorded in close co-operation with customers (preferably using Use- and Exposure Categories).

Moreover, CHEMETALL intends to develop detailed exposure scenarios if necessary.

Considering the close co-operation with our customers and the profound existing knowledge as to the use of CHEMETALL products, we are not going to develop complex questionnaires for the time being. In cases of missing information, we will contact our customers directly or complete the information together with our customers.

REACH Implementation Projects

REACH Implementation Projects (RIPs) will offer special guidance of how to implement REACH for the industry – they are to be considered non-mandatory guidelines for the REACH regulation. So far, not all RIP's have been completed. For this reason, CHEMETALL is presently not yet able to answer all questions in detail related to these REACH requirements.

Should you have questions regarding CHEMETALL products and REACH, please address these to your usual contact person or contact our REACH team:

REACH(at)chemetall.com