The REACH Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 and Directive 2006/121/EC of the European Parliament and of the Council of 18 December 2006 amending Council Directive 67/548/EEC were published in the Official Journal on 30 December 2006.
What is REACH?
Registration All chemical substances that are manufactured or imported (placed on the market) in the European Union in volumes of more than one metric tonne must be Registered. Registration involves the submission of specific test data and information to the European Chemicals Agency (ECHA).
Evaluation A process for checking that Registrations comply with the Regulation and if there is a need to generate more information on the properties of the substance involved.
Authorisation Substances with significant potential to cause damage to human health or the environment are subject to Authorisation. Authorisation allows the continued use of a substance for specified applications, under strict conditions. Authorisation will be regularly reviewed.
and Restriction Also applies to substances with significant potential to cause damage to human health and the environment. Restriction represents the inclusion of the current “Marketing and Use Directive provisions within REACH.
of Chemicals
To learn more about REACH, please consult the official ECHA Website:
http://echa.europa.eu/home_en.asp
PRE-REGISTRATION
Whilst REACH entered into force on 1st June 2007, the pre-Registration period commenced on 1st June 2008 and closed on 1st December 2008. During that period the IMCD Group, as a Distributor, has worked closely with its worldwide supplier base to ensure that the products we supply are REACH compliant. This has meant confirming that our suppliers, either directly or via their appointed Only Representative (OR), have either completed pre-Registration or that the substances they supply are exempt from REACH.
SIEFs and REGISTRATION
In general participation in a SIEF (Substance Information Exchange Forum) will be the responsibility of our suppliers (either EU-based manufacturers or an appointed OR for manufacturers outside the EU) who are currently working on Registration of their substances to meet the tonnage bands relevant for their pre-Registered substances.
Additionally, the IMCD Group has itself pre-Registered a limited number of substances and is participating in the relevant SIEFs to meet relevant Registration dates.
Substances of Very High Concern (SVHC)
According to Article 31 of the REACH Regulation:
“from the date of inclusion of any substance in the Candidate List, suppliers of that substance have to provide their customers with a safety data sheet (SDS).
Also, suppliers of preparations not classified as dangerous according to Directive 1999/45/EC have to provide the recipients, at their request, with a safety data sheet (SDS) if the preparations contain at least one substance on the Candidate List and its individual concentration is at least 0.1% (w/w) for non gaseous preparations (and at least 0.2% by volume for gaseous preparations).”
For products supplied by IMCD (substances and preparations), we have for many years already been communicating via the SDS the presence of components such as SVHCs (as they are CMR (Carcinogenic, Mutagenic and Reproductive toxic substances) or toxic for the environment). For the future we are committed to continuing to supply such information via our SDS mechanism. Consequently, when an SDS is amended by any of our suppliers to show the presence of such substances we will provide the information promptly to our customers.
Dowload the IMCD-letter here.
To request a Safety data sheet please send a email to: mailto:SDS@IMCDGROUP.COM
Link: ECHA Website with background information on SVHC
http://echa.europa.eu/chem_data/authorisation_process/candidate_list_en.asp
Use Descriptor System / Communication within the supply chain
The REACH Regulation requires (under certain conditions) the development of a Chemical Safety Assessment (CSA), demonstrating safe Use of a substance throughout its lifecycle. Considering the number of substances and the various Uses that have to be identified, a common framework is necessary to harmonize communication and to support effective and efficient information exchange on all Uses from all levels of the supply chain.
The IMCD Group is following the recommendations from CEFIC/FECC/DUCC on the alignment on uses, which is linked to the proposed Use Descriptor System developed by ECHA .
Download the IMCD-letter here.
REACH is a very complex piece of new European Regulation, we would be very pleased to assist you in fulfilling your legal obligations.
Contact us via e-Mail under REACH@IMCDGROUP.COM
Facts about Reach
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