REACH

  • REACH status at A. Schulman
  • Status on REACH
  • REACH useful links
  • SVHC status update

REACH status at A. Schulman

What is REACH?
REACH is the European Regulation for Registration, Evaluation, Authorization 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 1st December 2008.

The late preregistration period ended on the 31st of May 2017. At this moment, companies planning to register non-phase-in (new) substances or existing substances that have not been pre-registered have a duty to inquire with ECHA whether a registration has already been submitted for that substance.

Registration
REACH requires manufacturers and importers of chemical substances (≥1 ton/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 cannot 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
Authorization will be required for the prioritized substances of very high concern (SVHC) that are included in REACH Annex XIV.

Companies applying for authorization 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 these substances with safer alternatives or technologies, and prepare substitution plans, if appropriate.

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
  • Defense 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.
  • Medicinal products/devices, food or feeding stuffs that are subject to other major bodies of legislation.

Status on REACH

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 under REACH A. Schulman is defined as an importer of polymers, polymer mixtures and substances.

  

Pre-registration

Polymers are in general exempt from the obligation to register under REACH. 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% 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 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 EUPC (European Plastic Converters), is actively following up all regulations regarding our products, finished products as well as raw materials.  EUPC is the EU-level Trade Association, representing European Plastics converters. They manufacture plastics, semi-finished and finished products for an extremely wide range of industrial and consumer markets.

The above paragraph about REACH registration refers to products which are purchased by customers directly from 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 A. Schulman material into the European Economic Area by contacting the local Product Safety department.

SDS under REACH
A. Schulman does fully comply with all requirements under REACH concerning SDS (Safety Data Sheet).
We provide SDS for all products to our customers who have purchased directly from A. Schulman. 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 Safety Data Sheet:

SDS - Europe, Middle East, Africa
ProductSafety.EMEA@aschulman.com

SDS – USA, Canada
AMER.Regulatory.Requests@aschulman.com

SDS – Latin America
Ismael.Crispin@aschulman.com

SDS – Asia-Pacific
niko.chan@aschulman.com

REACH useful links

European Chemical Agency (ECHA):

https://echa.europa.eu/home

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

Further guidance:
https://echa.europa.eu/support/guidance

List of Substances of Very High Concern:https://echa.europa.eu/candidate-list-table

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 authorization 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 Safety Data Sheet.

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