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The new EU chemicals legislation for the Registration, Evaluation and Authorization of Chemicals came into force on June 1, 2007. Known as REACH, the legislation requires companies manufacturing or importing products in the European Union (EU) above certain volumes to register the substances and their uses with the newly created European Chemicals Agency (ECHA).
Registration requirements
Until December 1, 2008 companies will be able to pre-register their substances for REACH. Pre-registration will allow companies up to 10 years to complete the full registration process while continuing to market their products. The timing of the full registrations will depend on the volumes and, in some cases, the hazards of the chemical substances. Higher hazard and volume substances must be registered by December 2010, moderate volume substances by June 2013, and low volume substances by June 2018.
The list of highest hazard substances, to be included in Annex XIV of the REACH legislation (Substances Subject to Authorisation), is not expected to be published until sometime late in 2009. Until this time it will not be possible to definitively identify SVHCs (Substances of Very High Concern).
Air Products’ involvement
At Air Products, we have been preparing for the REACH legislation for some time. At this time we do not plan to withdraw any of our products from the European market and have worked with our suppliers to secure our raw material positions. We currently plan to pre-register, or have confirmation by other actors further up the supply chain of plans to pre-register, all the substances we make in or import into the EU.
Air Products manufactures and supplies a wide range of products that, under REACH terminology, would be described as substances, preparations or polymers. Due to the complex nature of some product compositions the final determination of which definition is most appropriate is still being determined and agreed across suppliers of common product-types.
Pre-registered products by segment
Through the links below you can access lists of products that will be covered by our pre-registrations. Please select the industry segment in which you are interested to access the product information.
If you cannot find your product or have a question about REACH, please contact our Product Information Center in the U.S. (PRODINFO@airproducts.com) or send an inquiry to REACH@airproducts.com. Additional information is also available through our REACH Frequently Asked Questions (FAQ).
At this stage we plan to register all our products from the lists above in accordance with the schedule provided by the legislation. It is too early at this stage to give a precise timetable for registration. There is a possibility that despite our efforts, supply conditions could change between now and the long-term registration deadlines of 2013 and 2018, resulting in some products not being registered as currently planned. Please be assured that, in such event, Air Products will make every effort to give as early warning as possible to manage such a transition.
Customer involvement in pre-registration
Air Products has all the necessary information to complete pre-registration and does not require additional information at this time from its customers.
Downstream Uses
It is not necessary to include information about our customers’ downstream use as part of our pre-registration process. However, it is an important element of full registration.
As part of the registration process Air Products will work with its customers to obtain information on downstream uses and exposure scenarios. This communication will follow the process being developed by Cefic (European Chemical Industry Association) and will include phases of information gathering, such as:
- Preparing a list of product uses which are known to Air Products
- Refining this list of uses in collaboration with key customers & industry associations
- Reviewing existing information to prepare tentative exposures scenario for identified uses
- Communicating these scenarios to key customers or trade associations to refine the content, and subsequently to downstream users so that they can ensure their uses will be covered
In order to prevent duplication of effort and delay, we encourage our customers to wait until we have contacted them about downstream uses so that we can effectively manage this key phase of REACH compliance. Due to the registration timetables, it may not be until after 2010 that there is further communication on this issue.
For more information about the REACH legislation and related guidance documents, please visit the ECHA website. |
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