What is REACH?
REACH is the European Regulation for Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force on 1st June 2007 to streamline and
improve the former legislative framework on chemicals of the European Union (EU). REACH aims for increased protection of human health and the environment from the
risks that can be posed by chemicals. This Regulation places greater responsibility on all actors in the industry to manage these. A. Schulman fully supports the targets of REACH.
Manufacturers and importers must pre-register substances that are already on the EU market (so-called phase-in substances), if they want to benefit from transitional arrangements that allow registering them at a later stage. Pre-registration also enables registrants to share data with other registrants and avoid carrying out redundant tests. The pre-registration period ended on 1 December 2008.
REACH requires manufacturers and importers of chemical substances (≥1 tonne/year) to obtain information on the physicochemical, health and environmental properties of their substances and use it to determine how these substances can be used safely. Each manufacturer and importer must submit a registration dossier documenting the data and the Chemical Safety Assessment to the Agency.
Legal entities outside the EU can not register a substance, except if they appoint a competent "only representative" to take up their responsibility.
Once the registration dossier has been received, the Agency may check that it is compliant with the Regulation and shall evaluate testing proposals to ensure that the assessment of the chemical substances will not result in unnecessary testing, especially on animals.
Where appropriate, authorities may also select substances for a broader substance evaluation to further investigate substances of concern.
Authorisation will be required for the prioritised substances of very high concern (SVHC) that are included in Annex XIV.
Companies applying for authorisation will have to demonstrate that risks associated with uses of these substances are adequately controlled or that the socio-economic benefits from their use outweigh the risks.
Applicants will also have to investigate the possibility of substituting theses substances with safer alternatives or technologies, and prepare substitution plans, if appropriate.
The European Union can impose restrictions and prohibit or set conditions for the manufacture, placing on the market or use of certain dangerous substances or group of substances when unacceptable risks to humans or the environment have been identified.
Communication in the supply chain
Suppliers of substances must pass on information on the health, safety and environmental properties and safe use of their chemicals to their downstream users (via a Safety Data Sheet or other means). Downstream users may only use substances classified as dangerous or which are persistent, bioaccumulative and toxic (PBT and vPvB) if they apply risk management measures identified on the basis of exposure scenarios for their use.
This Regulation shall not apply to
- radioactive substances
- substances which are subject to customs supervision
- non-isolated intermediates
- transport of dangerous substances
- Defence interests
Amongst others, the following substances are exempted from an obligation to register:
- Polymers but not the monomers;
- Substances of minor concern which are well defined and for which all pertaining data is available (as listed in REACH Annex IV and/or Annex V)
- Preparations i.e. formulations or mixtures where no chemical reactions are involved. However, the individual substances in such mixtures must still be registered);
- Substances in Articles provided the substances in the articles are not intentionally released under normal or reasonably foreseen conditions of use (coolant in refrigerators);
- Medicinal products/devices, food or feeding stuffs that are subject to other major bodies of legislation.
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Status on REACH at A. Schulman – January, 2017
Role of A. Schulman under REACH
Regarding the REACH regulation (Regulation (EC) No 1907/2006) A. Schulman is playing two main roles.
We understand ourselves mainly as a downstream user of European manufacturers and importers of polymers and substances.
In a second role A. Schulman under REACH we are defined as an importer of polymers, polymer mixtures and substances.
Polymers and polymeric preparations (mixtures like compounds and masterbatches), this means all A. Schulman products, in general under REACH regulation are exempt from the obligation to register.
Therefore all our polymeric products as such do not have to be (pre-)registered and we do not have a (pre-)registration number.
However all substances present in the mixture as well as all building blocks of the polymers (monomers) for our finished products have to be (pre-)registered.
We hereby can confirm that all monomers forming the polymer in an amount ≥2% weight by weight and also all relevant substances used in our products have been (pre-)registered by us or our suppliers.
Based upon the information received from our up-stream suppliers and the fact that for security reasons we have pre-registered a small number of substances and monomers ourselves, we can ensure future REACH compliant deliveries. This includes also the products of the Distribution Service.
Registration – Supply Chain Communication
To ensure compliance to the REACH Regulation, A. Schulman has taken the necessary steps either by verifying that our imported volumes are covered by our supplier’s Only Representative (according to art 8) or by taking up our responsibility in the relevant SIEF as required. We are well aware of the last registration deadline of 31 May 2018 and follow up closely with our suppliers if all substances will be registered in time. We will inform you accordingly.
Our product development process ensures that only raw materials are used for the production of our polymeric products which have been already (pre-)registered by its manufacturer or importer. A. Schulman, as a member of ETHIC (European Thermoplastics Independent Compounders Association), is actively participating in the Plastics Exposure Scenario Team (PEST). This team is representing the plastics industry supply chain as it includes the most important associations representing additive manufacturers/importers, compound manufacturers, masterbatch manufacturers, plastics converters and plastics producers.
PEST developed a very detailed mapping between the single downstream process operations and applications and the REACH User Descriptor system as published by ECHA. The mapping is available on http://www.plasticseurope.org/plastics-sustainability14017/consumer-protection/reach.aspx If your uses are covered there is no need to contact us on this matter as the identified uses will or have been evaluated by the substance manufacturer. Further work has been done to generate exposure scenario’s for mixtures in an efficient way.
The above paragraph about REACH registration refers to products which are purchased by customers directly from an A. Schulman affiliates in the European Economic Area. A. Schulman products imported into or placed on the market of the European Economic Area by customers either directly or as part of a preparation are not covered by this information. A. Schulman strongly recommend that customers should specifically assess their legal responsibilities under REACH when importing Schulman material into the European Economic Area by contacting the local Product Safety department.
MSDS under REACH
A. Schulman does fully comply with all requirements under REACH concerning SDS (Material Safety Data Sheet). We are able to provide SDS for all products to our customers who have purchased directly from A. Schulman the specific product. Actual Safety Data Sheets can also be requested from your known contact person in our Customer Service Department.
SVHC under REACH
The Substances of Very High Concern included in the Candidate List (SVHC Candidate List), published by the ECHA (European Chemicals Agency). A. Schulman does fully comply with all REACH requirements concerning SVHC (e.g. disclosure and communication of SVHC). Please contact us for our separate updated statement on SVHC or check the most recent Material Safety Data Sheet.
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REACH Useful Links
EuPC's REACH Club:
The Club's aim is to bring together people with good knowledge of REACH and with responsibilities related to its implementation in their companies.
PEST - Plastics Exposure Team
This website will provide you with useful information about the identified uses in the Plastic Supply Chain.
European Chemical Agency (ECHA):
CEFIC : European Chemical Industry Council
Links to helpdesks of EU countries:
List of Substances of Very High Concern:
SVHC status update
Substances that are included in the Candidate List have been identified as Substances of Very High Concern (SVHC). These substances may have very serious and often irreversible effects on humans and the environment. Substances on the Candidate List may subsequently become subject to authorisation by decision of the European Commission. You can find the link to ECHA's website with the candidate list under "REACH useful links". Since the candidate list will be regularly updated, we need to re-evaluate the presence of SVHC each time a new update is published. Please contact us for more information and our separate SVHC statement or check the most recent Material Safety Data Sheet.
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