REACH

The Chemicals Policy in the European Union

In the European Union (EU) chemical manufacturing is the third-largest industry, including 31,000 companies employing 1.9 million people.¹ Chemicals are important to the EU economy.

Use of these substances may pose risks. Recorded incidents of allergies, some cancers and reproductive disorders are on the rise in Europe, and chemicals may be a cause. In addition, studies show that some animals (frogs, birds, fish) suffer infertility and gender changes, related to certain chemicals affecting hormones.² 

More than 100,000 chemicals were on the EU market in 1981 - of which 30,000 are manufactured on a regular basis - and we know very little about them; information on 99% of these is insufficient today.³
 
To lessen risk and improve transparency, the European Commission has developed a regulatory system called REACH: Registration, Evaluation and Authorization of Chemicals. The intent is to better protect human health and the environment, while enhancing competition by fostering innovation and ensuring high safety standards for chemicals.

Requirements

REACH requires companies to take responsibility for the chemicals which they manufacture, import or supply in the EU. While a major part of the responsibility is with the original EU manufacturer of the chemical or the EU-based company that imports it into the EU, all organizations which mix chemicals into other products and users of those products also have obligations under REACH. They must submit information on properties, uses and safe handling. Working together and sharing data among companies is encouraged, for the betterment of the industry. Communication between suppliers and users of chemicals – the supply chain – is an essential part of REACH.

Pre-registration - The first stage of REACH

All substances currently in use in the EU must have been pre-registered by each manufacturer and importer before December 1, 2008. FAILURE to PREREGISTER means that you are no longer allowed to manufacture, import or supply in the EU. However it is possible to late pre-register substances which are manufactured and imported but only when the volumes are low (<100 ton/year).

Registrations - The second stage of REACH

All substances manufactured in or imported into the EU at more than one ton/year/manufacturer or importer have to be registered. This will involve the submission of a dossier of data to the ECHA in Helsinki. This dossier has to include data on the hazardous properties of the substance, its uses and, in most cases, a risk assessment (Chemical Safety Report) covering each different type of use. The actual data in the dossier and when the registration has to be submitted will depend on the hazards of the substance and the amount manufactured or imported by each company.

The first phase substances to require registration will be those classified under EU law as Category 1 and 2 carcinogens, mutagens and reprotoxins (CMR); those classified as R50/53, (Very toxic to aquatic organisms, may cause long term adverse effects in the aquatic environment) and manufactured or imported at >100 tons/year; and substances manufactured or imported at >1000 tons/year per manufacturer. These substances must have been registered by December 1, 2010.

The second phase substances to require registration will be those manufactured or imported at >100 tons/year – <1000 tons/year per manufacturer. These substances have been registered by June 1, 2013.

The third and last phase substances to require registration will be those manufactured or imported at >1ton/year – <100 tons/year per manufacturer. These substances must be registered by June 1, 2018.

Quaker Houghton submitted dossiers to ECHA in 2010 and in 2013 successfully and will submit dossiers in the coming years.

Evaluation - The third stage of REACH

There are two stages to an evaluation:

• Dossier Evaluation – The registration dossier will be checked for completeness and it will be decided if further information is required to complete the risk assessments.
• Substance Evaluation – The hazardous properties of a substance and the way that it is used will be subject to a detailed evaluation by the competent authorities in the EU member states. If there are no concerns, use of the substance will be allowed to continue. If there are concerns, additional information may be requested or controls on the use of the substance may be proposed. Substances will be prioritized for this evaluation based on their level of risk to human and environment. At this moment Quaker Houghton is awaiting the evaluation (dossier and substance) by ECHA. Quaker Houghton has re-submitted on request of ECHA some dossiers and in another case Quaker Houghton is in discussion with ECHA about the substance identity.

Impact

Raw material manufacturers are responsible for registration, so Quaker Houghton’s main task is to coordinate with suppliers on affected materials. We invest important resources to put into conformity our raw materials and range of products. Quaker Houghton may decrease suppliers or find safer alternatives. If some substances are discontinued, we will have to re-formulate products.

While this is currently an EU legislation, other countries like South Korea and Turkey are in the process to activate REACH like regulations, it will be a matter of time other countries will follow and span the globe. REACH already impacts Quaker Houghton beyond Europe. Epmar, AC Products, Summit Lubricants and G.W. Smith and Sons, Inc., our subsidiaries outside Europe, export products to Europe and therefore must comply with REACH.

We know EU-REACH has and will affect industry prices to a certain extent, and expect supplier costs to influence Quaker Houghton costs. However, the full implications will not be apparent until after the regulations (2018) are implemented.

Fact 1:  We need chemicals and a strong industry   Fact 2:  Chemicals can pose risks, but information is sketchy   Fact 3:  REACH regulation will provide an increased level of protection to mankin and the environment

Acronyms
ECHA: European Chemicals Agency
REACH: Registration, Evaluation and Authorization of Chemicals
CMR: Carcinogens, Mutagens and Reprotoxins
PBT: Persistent, Bioaccumulative and Toxic
vPvB: very Persistent and very Bioaccumulative
SVHC: Substance of Very High Concern

¹“Fact and figures – The European chemical industry in a worldwide perspective,” January 2005, European Chemical Industry Council (www.cefic.org/factsandfigures/).

^{2, 3} “Environment Fact Sheet: REACH,” 2006, European Commission.

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