- Although the first REACh registration deadline has passed some details need further clarification
- Baerlocher is carefully observing the developments in these REACh interpretations.
- 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.
- Baerlocher is an active member of several consortia to prepare the necessary registration dossiers.
REACh registration deadlines
- Pre-registration (1st June – 1st Dec. 2008)
- Registration (1st Dec. 2010) for substances
- manufactured/imported >1000 t/y
- CMR cat. 1A and 1B (>1 t/y) (carcinogenic, mutagenic, toxic to reproduction) classified with H400/H410 (>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
- all lead substances manufactured or imported have been successfully registered
- 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.
- many tin substances have already been registered, some require registration 2013 or 2018
- 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 are not affected by REACh.
- only registration and evaluation is required.