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REACH customer information

Ladies and Gentlemen,

On 1.6.2007, the REACH Regulation came into effect (Regulation 1907/2006/EC).

This letter is intended to provide information on the most important consequences of the regulation for the users of chemical products and answer specific questions associated with this specific topic.

Key points of REACH

The new European chemicals regulation, REACH, governs the registration, evaluation and authorisation of chemicals.

REACH is mainly aimed at the manufacturers and importers of chemical substances (i.e. mainly basic chemicals), who are obliged to register their products with the European Chemicals Agency and submit all relevant documents (including the evaluation of toxicological and ecotoxicological properties and hazard assessment taking the intended use into account, etc.).

The agency evaluates the registration documents and can, as part of an authorisation procedure – only in the case of substances giving cause for particular concern however (e.g. carcinogenic, mutagenic), restrict or prohibit the use of the substance.

The periods for registration of the substances depend on the manufacturing or import volume. They start on 1.6.2008 and, for small volume substances (< 100 t/a), initially end on 1.6.2018.

The consequences of REACH for our company and our customers

Registration: Our company does not synthesise any substances and is therefore not subject to mandatory registration. As a supplier of preparations, we are "downstream users" according to REACH. This status applies similarly to the users of our products. Our suppliers who synthesise or import the substances are responsible for the registration of the raw substances used by us. Preparations are not subject to registration.

Intended use of substances and preparations: We are required, according to REACH, to only use substances in our products that are registered for the intended use by the manufacturer. This obligation applies also to the users of our products who may only use them as intended. The provision of a description of the intended use of our products in safety data sheets and technical information leaflets has been standard practice at our company for a long time and we assume that our customers follow the information provided.

The intended use to be taken into account in the registration of the substances according to REACH will be defined more comprehensively than previously however. In the majority of cases, distinction will only be made between industrial, commercial or private use, so that the fields of application of our raw substances and in turn our products would normally automatically be covered. We certainly intend to examine this in detail and ensure that our products comply with the requirements with regard to the intended use of the ingredients.

Safety data sheets: The provision of safety information will continue with the aid of safety data sheets. The requirements of the previous safety data sheet directive (91/155/EEC) was included in the REACH Regulation, so that apart from interchanging Chapters 2 and 3, no particular changes have been made to the safety data sheets for preparations. Identification of the products will also remain unchanged until the next revision. In the case of the hazardous substances specified in Chapter 3, the registration numbers issued as part of the registration procedure will also be gradually included. In addition, further or new information concerning hazardous substance properties obtained in the course of the registration procedure will be included in the safety data sheets.

Availability of raw substances and products: It will not be possible for us, neither today nor at a later time, to obtain early assurances from the substance manufacturers and importers that they will register the substances we obtain from them and will continue to produce them in future. The pre-registration of a substance is also not a guarantee that the manufacturer will subsequently have the substance registered. Depending on the particular production volume, the manufacturers have to ten years to decide for or against registration. Once the registration period has ended, the manufacture of a non-registered substance must be discontinued. Since the raw substances we use are mainly established substances and are therefore not expected to be subject to use restrictions, we assume that the majority of our products will continue to be available without change. There has always been a certain amount of fluctuation in the availability of chemicals – whether through changes at the manufacturer or the influence of legislation. It is therefore a fundamental part of our development to meet the demands of our customers with a secure supply of our products by revision or further development of the formulations.

Specific consequences of REACH

Compared to the original draft regulations, the REACH Regulation, which has now come into effect, essentially has only the aforementioned indirect consequences for our company as a supplier of preparations and our customers as users of these products. With REACH coming into effect, no special measures are necessary at present.

REACH is a lengthy process that will certainly occupy the industry at least until the end of the registration period (2018). Any changes that could arise, e.g. through registration of the substances or different interpretations of individual clauses of the regulation, will no doubt occur over the course of this long period.

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