REACH, the EU Chemicals Regulation (EC 1907/2006), which entered into force on June 1, 2007, follows the principle of "no data no market." Under this regulation, a manufacturer or importer may market chemical substances in quantities greater than 1 tpa within the territory to which the regulation applies only if the substances have been pre-registered. REACH is based on the principle of giving greater responsibility to industry and applies generally to all chemical substances, regardless of whether or not they have hazardous properties.
In this connection, giving greater responsibility to industry also means that manufacturers and importers must assume responsibility for the safety of their chemicals and collect all data required for evaluation. In other words, industry must ensure that all foreseen uses along the product chain are managed safely, without endangering the health of downstream users, consumers, or the environment.
1. Pre-registration
To safeguard the continued, legal marketability of our entire product range, we, as a responsible company, have worked with great care to pre-register all the substances contained in our products. We ourselves pre-registered those substances which we manufacture or import; in the case of substances we purchase within the EU, we verified that our EU suppliers have also gone through pre-registration.
2. Registration
Pre-registration serves to provide a window of time for registration of what are referred to as "phase-in" substances (including existing chemical substances, EINECS substances). The registration deadlines are quantity-dependent.
Stage 1: registration until December 1, 2010 for:
- all substances >1,000 tpa,
- substances >100 tpa with N, R 50-53 and
- cmr substances in categories 1 and 2 in quantities >1 tpa
Stage 2: registration until June 1, 2013 for:
- all substances >100 tpa
Stage 3: registration until June 1, 2018 for:
- all substances >1 tpa
For the purpose of registration, a technical dossier must be completed for each substance, including the required toxicological and eco-toxicological studies as determined by tonnage. For all substances >10 tpa, a chemical safety report (CSR) is additionally required that includes the chemical safety assessment. If a substance is dangerous, or a PBT or vPvB substance, the CSR must further include an exposure assessment, which describes the identified uses of a substances in the form of exposure scenarios, including the conditions for safe use. After registration, these exposure scenarios will then be annexed to the correspondingly expanded safety data sheet.
Downstream users (DU) are then only permitted to apply these substances for their registered uses. If a DU ascertains some other use, he can request the supplier to subsequently register his use, or he can register it himself. All this means additional work. Avoiding it requires timely communication along the product chain.
3. Use descriptor system
The use descriptor system was established to simplify communication along the product chain and standardize information on uses for the various substances. It is based on five categories (descriptors):
- Sector of use (SU)
- Product category (PC)
- Process category (PROC)
- Article category (AC)
- Environmental release category (ERC)
A downstream user is entitled to make his uses known to his supplier. Because a DU cannot know when or if his supplier is required to register, for example, and the deadline for making uses known for substances in 2010 is at the end of November 2009, very many customers currently are announcing their uses to their suppliers (see also ECHA Europa Newsletter, October 14, 2009). To avoid duplicate work and unnecessary communication, we have compiled the typical uses for all RheinChemie products and formulated the relevant descriptors. These are summarized by division in the following three tables. The following industry models provided the basis for mapping the descriptors:
Lubricants Division: ATIEL/ATC industry model
ATIEL - REACH Generic Exposure Scenario
Rubber Division: WDK and ETRMA industry model
ETRMA - REACH - try
Engineering Plastics Division:
ISOPA - REACH
PEST - Plastics Exposure Team
Disclaimer
Rhein Chemie, based on the Use Descriptor System, has carried out an initial mapping of its sale products. The result is a working document for the REACH process. Only during the registration process will the information required to confirm the safety of identified uses be available. Should registration result in an unsafe use, we will inform you as soon as possible. (January 1, 2010; no 1.0)
