Facts

Messages

• Although the REACH legislation has entered into force many details need further clarification. 
   
• Baerlocher is carefully observing the developments in these Reach interpretation.  
  
  
• We are committed to meeting our legal obligations under REACH and have started preparing for it (since 2003).  
  
  
• We have ensured that all of our manufactured or imported products  entered the pre-registration to ensure the transition periods.
  
  
• We are in close contact with our suppliers to ensure that the purchased materials are pre-registered and registered as well.
  
  
• It is our intention to register our products as much as possible. If certain substances will be phased out, we inform our customers in due time.
  
  
• Identified use: has to be communicated from the customers to the suppliers to prepare the necessary risk assessments accordingly.
  
  
• If customers have special applications, which should be considered in the exposure scenarios, an early contact would be helpful. 
   
• Baerlocher is an active member of serveral consortia to prepare the necessary registration dossiers. 

Reach deadlines

• Pre-registration (1st June - 1st Dec.2008) 
  
  
• Registration (1st Dec.2010) for substances:
  manufactured/imported >1000 t/y
  cmr cat. 1 and 2 (>1 t/y) (carcinogenic, mutagenic, toxic to reproduction)
  classified with R50/53 (>100 t/y) (very toxic to aquatic organisms)
  
   
• Registration (1st June 2013) for substances:
  manufactured/imported >100 t/y
  
   
• Registration (1st June 2018) for substances:
  manufactured/imported >1 t/y

Stabilizer systems under REACH

Lead

• will require authorisation for sales within the EU;
  sunset date unknown yet (expected between 2010 and 2015);
  will probably require registration only for sales outside the EU;
  
  
• authorisation after sunset date unlikely to be granted because a substitution plan (Vinyl 2010) exists and no socio-economic benefit;
  it is expected that annex XIV will be used as a black list by certain parties as soon as published and give additional pressure on substitution.
  
  

• several substances will require authorisation;
  risk assessment showed no concern in rigid PVC applications;
  for the time being the EU Commission/member states are considering restrictions/use bans for certain applications; (decision expected in autumn 2008)
  
  
• food contact applications not affected by REACH.
  
  

• only registration and evaluation required.