How Reach Regulations Impact Exports

REACH stands for Registration, Evaluation,Authorization and restriction of Chemicals and it took effect on June 1, 2007. It is a regulation of the European Union (EU) and it establishes the procedures for collecting and assessing information on the properties and hazards of substances; it is a system for controlling chemicals in the EU. Any company can be affected by REACH so it is important to understand where your company fits in the supply chain – this will determine what you have to do and when you have to do it. Under REACH, companies play one of four roles: manufacturer of chemicals; importers buying from outside the EU; downstream users using chemicals within the EU; and those companies outside the EU doing business with importers. To comply with the regulation, companies must identify and manage the substances they manufacture and market in the EU.

What substances and chemicals require registration?

EU manufacturers and importers of substances and mixtures need or will need to register their materials with the EU once a substance is manufactured or imported at levels above 1 metric tonne/year. Currently, registration for substances between 1 tonne/year and 100 tonnes/year are due in 2018; other levels have already completed registration. Registration requires the submission of various chemical properties and toxicological testing of the pure substances. Articles that are imported into the EU do not need to register the substances that comprise the article.

I don’t sell substances or chemicals. Why should I care about REACH?

If your company sells an article that is destined for the EU, and that article contains a chemical found on the list of REACH SVHC substances, you should pay attention to REACH and determine what obligations you have for compliance as part of the supply chain of a REACH substance.

What are the REACH SVHC substances?

SVHCs, or Substances of Very High Concern, in general terms are substances that have been deemed to pose risks to human health or the environment. If a substance meets the criteria for classification as a SVHC, it is placed on something called the “Candidate List”. The list is updated every 6 months (in June and December) and it currently has 155 substances on it; visit the European Chemicals Agency website for complete details.

How does this affect my products?

Once a substance is placed on the Candidate List, specific responsibilities are placed on industry. Generally this means that suppliers of a SVHC substance have a duty to communicate information on substances in articles, mixtures, or on the substances themselves. This information can be in the form of a safety data sheet (and possibly instructions for safe use) and provided to the supplier’s customer when the SVHC is found in a concentration greater than 0.1% by weight of the article.

Furthermore, suppliers of articles containing substances that appear on the Candidate List may need to submit a notification to the ECHA and register the substance. Notification by the producer or importer of the article is required when the following conditions are met:

1. The substance is on the Candidate List and
2. The substance is present in the article above a concentration of 0.1% by weight and
3. The total amount of the substance in the article exceeds one tonne per producer or importer per year and
4. The substance has not been registered for that specific use

What role does Teknor Apex play as a supplier of PVC compound or film?

Teknor Apex has a regulatory department dedicated to keeping track of the constantly changing regulatory environment and to making sure that the company, the materials we buy and the products we sell comply with state, federal and international laws, reporting requirements and regulatory restrictions. The current Candidate List contains 2 substances (DEHP and Trixylyl phosphate) that are used in certain Teknor Apex PVC formulations. If a Teknor Apex product contains any SVHCs, that disclosure will be on the product’s Safety Data Sheet (SDS). Should you have any questions about REACH compliance for the compound or film you buy from Teknor, send an email with your question to vinyl@teknorapex.com.