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REACH @ RAVAGO
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Ravago is fully aware of its obligations as a manufacturer/importer/downstream user. Our first priority is to meet our legal obligations under REACH, as well as to ensure that the supply of materials to our customers is not interrupted.
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What is REACH?
REACH is a new European Union regulatory framework for Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force on 1st June 2007 to streamline and improve the former European legislative framework on chemicals. REACH places greater responsibility on industry to manage the risks that chemicals may pose to the health and the environment.
REACH also creates the European Chemicals Agency (ECHA) which has a central coordination and implementation role in the overall process. ECHA is located in Helsinki, Finland, and will manage the registration, evaluation, authorization and restriction processes for chemical substances to ensure consistency across the EU (feel free to visit the ECHA website @ http://echa.europa.eu and choose your preferred language. Note that the most detailed information is available in English).
Why REACH?
REACH replaces about 40 pieces of legislation with a streamlined and improved Regulation. Other legislation regulating chemicals (e.g. on cosmetics, detergents) or related legislation (e.g. on health and safety of workers handling chemicals, product safety, construction products) not replaced by REACH, will continue to apply. REACH has been designed not to overlap or conflict with the other chemical legislation.
The aims of REACH are to :
- improve the protection of human health and the environment from the risks that can be posed by chemicals,
- enhance the competitiveness of the EU chemicals industry, a key sector for the economy of the EU,
- promote alternative methods for the assessment of hazards of substances,
- ensure the free circulation of substances on the internal market of the European Union.
REACH in practice
REACH is based on the idea that industry itself is best placed to ensure that the chemicals it manufactures and puts on the market in the EU do not adversely affect human health or the environment. REACH makes industry bear most responsibilities to manage the risks posed by chemicals and provide appropriate safety information to their users.
All manufacturers and importers of chemicals must identify and manage risks linked to the substances they manufacture and market. For substances produced or imported in quantities of 1 tonne or more per year per company, manufacturers and importers need to demonstrate that they have appropriately done so by means of a registration dossier, which shall be submitted to the Agency.
Once the registration dossier has been received, the Agency may check that it is compliant with the Regulation and shall evaluate testing proposals to ensure that the assessment of the chemical substances will not result in unnecessary testing, especially on animals.
Where appropriate, authorities may also select substances for a broader substance evaluation to further investigate substances of concern. Manufacturers and importers must provide their downstream users with the risk information they need to use the substance safely. This will be done via the classification and labelling system and Safety Data Sheets (SDS), where needed.
Use of non-registered substances and non-registered uses after the corresponding deadline, will be prohibited. No data, no market !
Chemicals covered by REACH?
In principle REACH applies to all chemicals: not only chemicals used in industrial processes, but also in our day-to-day life, for example in cleaning products, paints as well as in articles such as clothes, furniture and electrical appliances.
REACH applies to the manufacture, sale or use of substances on their own, in preparations or in articles. REACH follows a substance based approach: the obligations do not directly apply to preparations and articles but to the substances contained in them.
REACH applies to all substances with a few exemptions (not limited):
- radioactive substances
- substances under customs supervision,
- non-isolated intermediates
- waste ( for details please read "Reach and waste")
A number of other substances are exempted from parts of the provisions of REACH, where other equivalent legislation applies (for example substances used in medicinal products).
REACH and polymers
Polymers do not have to be registered, but this does not mean they are exempted from the scope of REACH !
Under REACH, the monomer "building block" as well as any other substance that has been reacted into the polymer backbone needs to be registered, if not already registered by an actor up the supply chain and if they are part of the polymer for more than 2% weight by weight and produced/imported in a volume of more than 1 ton/year. For that reason polymer additives need to be registered if they are manufactured or imported on their own or in compounded form in volumes of 1 ton/year.
Please note that the plastic/rubber materials as produced/imported by Ravago are preparations. Under REACH preparations do not need to be registered separately. Once again, only the substances, used on their own, are subject to registration obligations.
REACH and waste
Since waste (production waste, post consumer waste,...) is not a substance, a preparation or an article within the meaning of REACH, waste can be considered as an exemption from the REACH requirements.
But when undertaking recovery of waste plastics, the substances constituting the recycled polymer must be registered*. This means that the recycled polymer falls within REACH and its requirements are to be fulfilled, resulting in many practical problems. For a start there is a break in the chain of information relative to waste recovery operations whose operators do not receive SDS. Because of mentioned exemption, waste "suppliers" are not obliged to send SDS to the recycler! For the moment it is still unclear how the European Commission will proceed on this issue in particular and other waste issues related to REACH in general.
(* It is worth noting that this exemption does not require that the substances have been registered by an actor in the same supply chain. It is sufficient that a registration was made for the substance, either by an actor in the same supply chain or by a company in another supply chain.)
REACH timeline
Ravago is working very closely together with local and European sector organisations to try and find simple and cost effective solutions to the problems of working with waste within REACH. Whenever more guidance or information would be available, it will be shared with our customers at this webpage.
After entry into force of REACH, manufacturing and import of substances in quantities ¡Ý 1 tonne per year can only take place if the substance is registered.
Phase-in substances ( i.e. substances which have long been on the EU market ) and the non-phase in substances however, have different timelines for registration under REACH.
Phase-in substances : pre-registration
For phase-in substances a transitional arrangement has been made. In order to benefit from this transitional arrangement substances need to be pre-registered between 1 June 2008 and 1 December 2008. Pre-registration allows companies to continue manufacturing and importing their phase-in substances for several years until the registration deadline is reached.
A list of all pre-registered substances will be published on the ECHA website by 1 January 2009.
Registration
or phase-in substances which are manufactured or imported in a quantity of 1 tonne or more per year and which have been pre-registered, the registration provisions will apply in a stepwise way to facilitate the transition to REACH:
- substances manufactured or imported > or = 1000 tonnes/year as well as Carcinogenic, Mutagenic or Reprotoxic substances category 1 and 2 (CMR cat 1 and 2) manufactured or imported at or above 1 tonne/year, or substances classified as dangerous for the aquatic environment with R50/53 and manufactured or imported at or above 100 tonnes/year will have to be registered before 1 December 2010,
- substances manufactured or imported in volumes of 100 to 1000 tonnes/year will have to be registered before 1 June 2013,
- substances manufactured or imported in volumes of 1 to 100 tonnes/year will have to be registered before 1 June 2018.
Substances which have not previously been placed on the EU market (non phase-in substances), and phase-in substances which have not been pre-registered, must be registered before they can be manufactured, placed on the market or used!
REACH guidance?
For a smooth implementation of REACH several guidance documents have been developed. These guidance documents were drafted and discussed within projects lead by the European Commission services, involving stakeholders from Industry, Member States and non-governmental organisations. The finalised guidance documents are published and can be downloaded at the ECHA website :
http://reach.jrc.it/guidance_en.htm
For more detailed (product) information, please contact our REACH focal points at reach@ravago.com
REACH @ Ravago
REACH and the impact it has on the future availability of chemicals in general and polymers in particular, is an issue of significant importance for Ravago, our suppliers and our customers. Joint collaboration across all supply chains will be required.
We as Ravago are fully aware of our obligations as a manufacturer/importer/downstream user. Our first priority is to meet our legal obligations under REACH, as well as to ensure that the supply of materials to our customers is not interrupted.
Ravago is currently intensively communicating with its raw material suppliers to find out their intentions regarding the pre-registration and registration of the substances used in the manufacturing of materials they supply to us. To help facilitate the efficient exchange of information, we have developed a secure web application to collect pre-registration information from our suppliers.
Once we have gathered and processed the received data, we will make this information available for our customers. They will be able to consult a regularly updated "REACH-status" of the products Ravago supplies to them, based upon the information we (will) receive from our suppliers.
A link to the Ravago REACH customer tool will be availble soon.
In a later stage we will also start communicating with our own suppliers and customers to gather more detailed data on downstream uses, like conditions of use & exposure scenarios. Further information and/or questionnaires on these items will be communicated at a later stage.
Meanwhile we wish to thank our customers for their understanding, that from a point of workload and efficiency, we cannot answer their questionnaires individually, and for their cooperation on this complex but very important issue.
If you should have any further questions or remarks, don't hesitate to contact the REACH focal point for Ravago:
reach@ravago.com
Important notice : the information given on this webpage is based upon public information provided by the ECHA. No legal rights can be derived from it and Ravago disclaims any liability for any errors or omissions.
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URL: http://reach.jrc.it/guidance_en.htm
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Email: reach@ravago.com
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