REACh

What is REACh?

REACh is the European Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals. Having entered into force on 1st June 2007, it streamlines and improves the former legislative framework on chemicals of the European Union (EU). The main aims of REACh are to improve the protection of human health and the environment from the risks that can be posed by chemicals. Furthermore REACh enhances the promotion of alternative test methods, the free circulation of substances on the internal market and fosters competitiveness and innovation. REACh makes industry responsible for assessing and managing the risks posed by chemicals and providing appropriate safety information to their users. In parallel, the European Union can take additional measures on highly dangerous substances, where there is a need for complementing action at EU level. 

REACh Links

Verband der Chemischen Industrie e.V.

www.vci.de

Bundesanstalt für Arbeitsschutz
und Arbeitsmedizin


www.baua.de

European Chemicals Agency (ECHA)

www.ec.europa.eu/echa

REACh Facts

Messages

  • Althoughtwo REACh registration deadlines have 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 uses have 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

Lead

  • All lead substances manufactured or imported have been successfully registered
  • Will require authorisation for sales within the EU;
  • Sunset date unknown yet (expected between 2016 and 2020);
  • Authorisation after sunset date unlikely to be granted because a substitution plan (Vinyl 2010 and Vinyl plus) exists and no socio-economic benefit;

Tin

  • Many tin substances have already been registered, some require registration 2018
  • Several substances will require authorisation;
  • Risk assessment showed no concern in rigid PVC applications;
  • Specific restrictions/use bans for certain applications are in place
  • Food contact applications are not affected by REACh.

Ca-based

  • Only registration and evaluation is required.

Baerlocher and REACh

We are committed to meeting our legal obligations under REACH and have started preparing for it since 2003. A special task force has been built up to coordinate all REACH activities within the Baerlocher group of companies.  

Although the REACH legislation has entered into force and the two registration deadlines have passed some details need further clarification. A lot of guidelines have been published and updated, but further explanations and interpretations are needed. Baerlocher observes the REACH environment carefully.

We are actively participating in national and international working groups (e.g. VCI, ESPA, APAG).   We have pre-registered all of our manufactured or imported substances to guarantee the transition periods until 2018. It is our intention to register our products as much as possible. In this context we are in close contact with our suppliers to ensure that the purchased materials will be registered as well. If certain substances will be phased out, we shall inform our customers accordingly.