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REACH

Registering chemicals for the European market 

Houghton is committed to timely compliance with Europe’s REACH regulations (No. 1907/2006) concerning the safe use of chemicals within the European Union and European Economic Area (EU/EEA). The primary purpose of REACH is to improve the protection of human health and the environment through a system of Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) while maintaining the free movement of goods in the EU Market. 

What is REACH?

REACH regulations apply to EU substance manufacturers, EU importers (if you buy substances from non-EU suppliers, you are an importer) and downstream users to ensure the responsible supply and use of substances. 

The regulations apply directly in all 28 member states of the EU in addition to Iceland, Liechtenstein, and Norway as member countries in the EEA. The implementation of the regulations began in 2007 and will be complete in 2018. 

While REACH is limited to the EU/EEA, the legislative landscape globally is moving towards similar regulations.  Countries like China, Taiwan, Korea, Malaysia, Russia and Turkey have or are in the process of adopting more stringent chemical registration requirements to more effectively manage risks related to public health and the environment.  Similar to REACH in Europe, these regulations tend to require notifications, registrations of substances and/or mixtures, additional data requirements, and communications within the supply chain and with downstream users.

What is REACH Registration?

Generally, anyone who manufactures or imports substances into the EU above 1 tonne per annum (tpa) is required to register its substances with the ECHA (European Chemicals Agency). Implementation of REACH follows a phased-in approach based on tonnage bands. The pre-registration of phased-in substances took place from June 1, 2008 to December 1, 2008. Upon completion of pre-registration, three registration phases were established:

  • Phase 1: pre-registered substances ≥ 1,000 tpa, CMR cat 1 & 2 ≥ 1 tpa and R50/53 substances ≥ 100 tpa completed registration by December 1, 2010.
  • Phase 2: pre-registered substances ≥ 100 tpa completed registration by June 1, 2013.
  • Phase 3: pre-registered substances ≥ 1 tpa must complete registration by June 1, 2018. Hence the final phase of REACH is often now referred to as REACH 2018.

  

Who has to comply with REACH?

Any entity that purchases, manufactures, imports or uses chemicals in the EU/EEA is affected by REACH and has some obligations to fulfill. REACH compliance depends on your role in the supply chain and may vary for each hazardous product used or placed in the market. Sometimes you may be a manufacturer or importer, sometimes a formulator, and at a minimum an end user. For each chemical purchased or placed in the market in the EU/EEA, ask the question, “Am I a manufacturer, importer, formulator, distributor or customer/end user?”

Manufacturers and importers carry the most responsibility under REACH because they are required to register substances that they manufacturer and/or import into the EU/EEA above the one tpa limit. Formulators, distributors and customers/end users also have obligations to fulfill under REACH.

How is Houghton affected by REACH?

Houghton is primarily considered a “formulator” under REACH. Formulators are downstream users who produce chemical mixtures and sell them further down the supply chain or directly to consumers. As a formulator, Houghton’s primary task is to work with our suppliers to accomplish the following:

  • Confirm the registration status of the raw materials used in our formulations
  • Check whether the exposure scenarios provided by our suppliers cover our uses and our customers’ uses. These exposure scenarios are typically provided as an “extended” safety data sheet or eSDS.
  • Where supplier exposure scenarios do not cover our end uses, we work closely with our suppliers to get our uses covered or to develop our own chemical safety report (CSR) and/or exposure scenarios where they may be required.
  • Communicate the hazards of our mixtures to our distributors and downstream end users.
  • Incorporate exposure scenario information from our suppliers’eSDS within 12 months of receipt.

Working together to ensure regulatory compliance

Houghton encourages customers and distributors to consult their regulatory advisors and legal counsel regarding specific actions they may need to take during the final transition phase of REACH implementation. Our sales professionals and regional experts in product safety and regulatory affairs are available to answer your questions regarding our products and compliance with REACH. Please email ProductStewardship@houghtonintl.com for additional information regarding REACH and Houghton’s other programs supporting the safe use and handling of our products.