What is REACH
On June 1st 2007 the new European REACH regulations have come into effect in phases. REACH stands for Registration, Evaluation and Authorization of chemical substances. This is the new European Regulation which replaces the previous rules, such as the environmentally dangerous chemical law of the Netherlands (Wms). The goal of REACH is the protection of people as well as the environment against the dangers of chemicals.
Companies will have the responsibility, on the basis of information on characteristics and use, to expose and map the risks of chemicals. Based on this the necessary measures will need to be taken for the purpose of protection of man and environment.
What is pre-registration
REACH obligates producers and importers of chemicals (>¬ 1 ton/year) to gather information on the physical/chemical, health and environmental characteristics of their chemicals and, based on this information determine how these chemicals can be used in a safe manner. All producers and importers must supply an application dossier to the Agency in which the data and the determinations have been documented. All companies that pre-register a chemical become members of the information-exchange forum for that particular chemical (SIEF = Substance Information Exchange Forum) which is intended to prevent duplicate work performed in testing. The companies are obligated to make the results of animal testing supplied to the SIEF available to other companies in order to keep testing to a minimum. It is also possible to exchange other types of data. Pre-registration can be done up to November 30th.
What is registration
Over a period of 11 years REACH will maintain the registration of some 30.000 chemical substances. For this purpose producers and importers will have to supply the data and characteristics for each chemical substance of which more than 1 ton is produced or imported into the EU. The registering party will also have to identify the applicable risk management measures and inform the users thereof.
The burden of proof will be transferred from the government to the industry. REACH will furthermore make the further evaluation of chemical substances, which may cause any measure of concern, mandatory. The approval system will obligate companies to progressively make a transition to safer alternatives as long as these are already in existence. All requests for approval need to include an analysis of possible alternatives as well as a plan for the replacement of the substance as soon as appropriate alternatives become available. The existing restrictions in relation to usage of the substance continue to be enforced by REACH.
REACH distinguishes four categories within the substance supply chain:
- A producer; an established individual or a corporation which produces a substance in a community.
- An importer; an individual established in the Community or a corporation which is responsible for the importation of a substance.
- A downstream user; each individual established within the Community or a corporation, not being a producer or an importer, which uses the substance for the purpose of industrial activities or occupational activities.
The downstream users can be sub-divided in four sub-categories:
- Formulators: companies which process the substances or preparations into other preparations such as producers of paint, varnish, wax and cleaning products, glue, fire fighting products/retardants and cosmetic products.
- Professional users: companies that offer services such sanitation services, painting, upholsterers, nursing homes & hospitals and road construction companies.
- Industrial users: users of chemical substances and preparations in the industry such as the wood industry, car manufacturing, video-monitor/electronics manufacturing and the agriculture and gardening sector.
- Producers of items & objects: companies producing items which contain chemical substances such as toner cartridges, air fresheners, ink cartridges for pens.
- A distributor; each individual or corporation established in the Community, including retailers that exclusively store and offer the supply of substances or preparations to third parties.
Which categories does LDM have within REACH?
- Importer (substances)
LDM imports substances from beyond the EU borders. REACH is a European regulation; all chemical substances (> 1 ton/year) which are imported from outside the EU, need to be registered. LDM has in the meantime pre-registered all its metals.
- Downstream user; industrial user (auxiliary agents)
LDM imports no auxiliary agents (oils/chemicals) from outside the EU, so therefore LDM does not need to register this.
- Downstream user; formulator (brass metals)
Alloys do not need to be registered as preparations. But the composite metals do need to be registered if the used/imported quantity > 1 ton per year.
LDM will pre-register all the metals which will be utilized. LDM has in the meantime pre-registered all its metals.
- Downstream user; producer of objects (articles)
REACH considers drill steel and billets to be objects. REACH is only applicable in this case if substances of great concern are within the objects which are to be subsequently released. With our drill steel and billets this is not the case.
Within the framework of REACH, LDM has taken all necessary measures in order to continue manufacturing its products safely in the future.
For further questions regarding REACH, get in contact with our sales department.