What is REACH?
How will it work?
How will it affect your & our business?
But, most important, how can Akzo Nobel help you in the phases of REACH?
Answers to these questions, and more specific information with respect to our Dissolvine® products can be found in the enclosed document.
For our overview on planned pre-registration & registration of the substances of our products, click here.
WHAT IS REACH?
The European Community has reformed the previous European legislations for ‘existing’ (EINECS) and ‘new’ (ELINCS) substances, into one new uniform regulatory system for the Registration, Evaluation, Authorization and restrictions of Chemicals (REACH). The REACH regulation came into force on June 1st, 2007. REACH makes manufacturers, importers and their customers responsible for the safe use of chemicals. The producers and importers have to assess the risks of their substances over the entire supply chain and have to demonstrate that those risks are properly managed. The authorities will control this process by means of the registration dossiers to be submitted by the producers or importers and take additional measures on highly dangerous substances, where needed.
REACH is;
• providing an improved protection to human health and the environment
• increasing knowledge about the properties and uses of existing substances
• establishing an efficient risk assessment process
• requiring the registration of all substances manufactured or imported in quantities of 1 ton or more per year.
HOW WILL REACH WORK?
Registration requires gathering data on physicochemical, toxicological and ecotoxicological properties of substances as well as specifying individual identified uses and assessments of the associated risks and safety measures connected to these uses.
Manufacturers and importers have to submit this information to the European Chemicals Agency (ECHA) in Helsinki.
Essential parts of the registration dossier are:
• a Technical Dossier (for substances > 1 ton/y)
• a Chemical Safety Report (for substances > 10 ton/y)
The agency may then check that the registration dossier complies with the REACH Regulation and must evaluate testing proposals to ensure that the assessment of the chemical substances will not result in unnecessary animal testing. Where appropriate, authorities may select substances for an in-depth evaluation. Substances of very high concern shall not be used and have to be replaced by safer alternatives unless they get an authorisation for certain uses. Substances of very high concern are defined as carcinogenic, mutagenic or reproductive toxicants; substances that are persistent, bioaccumulative and toxic; or substances of equivalent concern. In addition the authorities may impose restrictions on the manufacture, use or marketing of substances causing an unacceptable risk to human health or the environment.
THE MAIN STAGES OF REACH
REACH includes a ‘no data, no market’ principle. Manufacturers and importers have to present data and register all substances that they produce or import at volumes of one ton per year or more. ‘New’ substances that were already notified under the previous legislation will be considered as being registered and receive a registration number. After pre-registration the ‘existing’ substances (now being mentioned phase-in substances) are granted with a delayed registration period on a phased basis over a period of 11 years.
INFORMATION FLOW
Under the new legislation the final target for information transfer to downstream users (= customers) will be the new extended Safety Data Sheet (eSDS) including the relevant exposure scenarios from the Chemical Safety Report covering all identified uses.
COMMUNICATION
The formation and communication within consortia (= groups of producers/importers of a substance) is a key issue within REACH, and our long experience as an active member of chemical industry associations means that we are prepared for the procedures and tasks that will be required. This is also of great significance when the obligatory SIEFs (Substance Information Exchange Forums) are formed at the end of the pre-registration period.
Also the communication over the supply chain is a very important part of REACH. Downstream users (customers) have the duty to inform the producer on the use of a substance, or have to register their specific use themselves.
HOW CAN WE HELP YOU?
In order to keep the administrative burden of the interactive communication between suppliers and down stream users to a minimum we intent to develop tentative exposure scenarios for the main uses of our products and subsequently for additional applications, based on our in-house knowledge. This is fully in line with the proposals/ recommendations done by CEFIC on communication in the supply chain.
In a second phase we will discuss these tentative exposure scenarios with key customers and/or trade associations in order to refine their content.
In the last phase we will communicate the refined draft exposure scenarios to all our customers for their review on whether their uses are covered and on the appropriateness of the use description and possible risk management measures.
In conclusion: our internal REACH implementation organization and processes are already in place. We have already carried out a thorough review of our product portfolio and substance data and we will contact you in due time with our tentative exposure scenarios.
Please see our overview on the planned pre-registration and registration scenario's of the substances in our products. Click here.