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REACH Registration 2018:


Supply concerns still loom large


Susanne Baker Chair, REACH X Sector Group


Despite Brexit, UK Government has been clear that the legal requirements to register substances in 2018 under the Regulation for the Registration, Evaluation, Authorisation and Restriction of Chemicals still stands. Companies reliant on niche chemicals and formulations are warning of possible supply risks following the deadline.


Despite its flaws, the EU’s regime for chemical legislation, REACH is arguably one of the best in the world, unlocking unprecedented information on the characteristics of chemicals which we, as companies and organisations that represent downstream users of chemicals, can use to make workplaces safer for workers, products safer for consumers and minimise adverse risks to our water, soil and air.


While there has been recent and ongoing debate about the regulation of chemicals following our departure from the European Union, UK government has retained a clear position about compliance with REACH: companies must continue to comply with it and must observe the third and final tranche of Registration that is fast approaching in 2018.


The registration process under REACH requires manufacturers and importers that are placing substances on the market to develop comprehensive dossiers on them. Data must be obtained to assess its risk to the environmental and to human health. To minimise animal testing, a single registration dossier is prepared for each substance: this means all companies that import or make a particular substance must work together in Substance Exchange Information Fora (SEIFs) to generate data.


Once all the required data is generated (and this could take several years) substances must then be correctly classified and instructions on how to safely use the substances in all of its various applications and uses must be outlined in enhanced safety data sheets which are cascaded down the supply chain. To ensure that this can be done, downstream users must ensure that their suppliers are clear as to how they use the substances they purchase from them.


There are two absolutes that emerge from Registration: first, substances that aren’t registered can not be used in the European Union. Secondly, if a use isn’t outlined in a safety data sheet it cannot be performed. So while registration is an activity which rests primarily with chemical manufacturers, it is also vitally important for downstream users. If registration of a substance doesn’t happen or isn’t comprehensive, it could see certain activities stop.


The first registration deadline focused on bulk chemicals, those placed on the market in quantities over 1,000 tonnes a year. The second registration deadline then dealt with those substances placed on the market between 100-1,000 tonnes. The final registration deadline under REACH in 2018 will see tens of thousands of niche chemicals being registered: those used in quantities of 1-100 tonnes. So far, over 11,000 unique substances have been registered. We are expecting the same, if not more to, be registered by 2018.


As the users of these substances, their continued supply is foremost in our minds. In previous registration rounds we


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LUBE MAGAZINE NO.141 OCTOBER 2017


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