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.

Pre-registration
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.

Registration
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.

Evaluation
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.

Authorization
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.

Restriction
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.

Exemptions
This Regulation shall not apply to

• radioactive substances
• substances which are subject to customs supervision
• non-isolated intermediates
• transport of dangerous substances
• Waste
• 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

I. Pre-registration

Compounds and Masterbatches in regulatory terms are considered as preparations. A preparation has to be understood as a mixture of substances with different chemical identity.

Preparations have not to be pre-registered or registered. However, if a company manufactures or imports a preparation into the EU market they have to ensure that all components of the preparation are pre-registered or registered.  Without the pre-registration or registration of single substances, further sale of the preparation is not longer allowed and possible.

Accordingly, A. Schulman has taken necessary measures to ensure pre-registration and registration of such materials. The pre-registration period ended on November 30^th 2008. 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 ourselves, the availability and supply of all substances for our products has been assured. This includes also the products of the Distribution Service.

II. 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 SIEFs as required. When new raw materials are introduced in our production process, the REACH status is checked prior purchase. For substances having a registration deadline of 1^st of Dec 2010, the registration numbers have been requested to our suppliers.

A. Schulman, as a member of ETHIC, is actively participating in Plastics Exposure Scenario Team (PEST). This team represents the plastic supply chain and includes the most important associations representing additive manufacturers/importers , compounders, masterbatchers, plastics converters and plastics producers. PEST has delivered a detailed mapping between the plastic processes and applications and the REACH User Descriptor system as published by ECHA. The mapping is available on http://pestpublic.plastics.net/public/ . 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.

III. SVHC

See separate statement on SVHC

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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.
www.reachclub.eu

PEST - Plastics Exposure Team
This website will provide you with useful information about the identified uses in the Plastic Supply Chain.
http://pestpublic.plastics.net/

European Chemical Agency (ECHA):
http://echa.europa.eu/home_en.asp

CEFIC : European Chemical Industry Council
http://www.cefic.be/en/REACH-implementation.html

Further guidance:
http://guidance.echa.europa.eu/

Links to helpdesks of EU countries:
http://echa.europa.eu/help/nationalhelp_contact_en.asp

List of Substances of Very High Concern:
http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp

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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 "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.

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