REACH Directive

The Registration, Evaluation and Authorisation of Chemicals (REACH) Directive came into force on 1st June 2007. This legislation is complex and far reaching in its requirements and implications. Its purpose is to evaluate the health and environmental impacts of all chemicals offered to the market in the EU and ensure that these impacts are minimised.

There are two main aspects to REACH:

• Firstly, the completion of an impact evaluation for all chemicals marketed in the EU by submitting dossiers to the new European Chemicals Agency (EChA).
• Secondly, communicating the results of dossier assessment up and down the chemical supply chain in order to minimise risks associated with the use of chemical products.

The first stage of dossier generation is pre-registration of all chemicals with the EChA scheduled to begin in June 2008 and to be completed by the end of November 2008. The submission of complete dossiers will then be scheduled to commence in three groups starting with the materials expected to produce the most significant adverse impact, i.e. 1,000 tonnes per annum and with the highest hazard classifications.

The EChA is expected to request dossier submission for this group within the first 3 years after pre-registration. The next group will be requested within 6 years of pre-registration and the final group with 11 years of pre-registration. The complete process is expected to take up to 15 years or more.

Equilibrium Chemical Services Limited is not a prime manufacture of chemicals, but a formulator. At the present time, we have established via our suppliers that, raw materials used by us are expected to be supported through the REACH process. We will be following this up through to the pre-registration process in 2008.

At the present time we do not use any raw materials that fall into the highest health or environmental risk categories requiring authorizing (CMR, PBT and VPvB) and we shall continue to pass on existing hazard information in the normal manner via product material safety data sheets, as required under REACH. There is little more that we can do at this stage.

Meanwhile, some of our customers are asking for supply chain information in order to prepare themselves for REACH. We will co-operate with these requests where we can, but the purpose of the supply chain information is to disseminate fully the hazards identified by the dossier and substance evaluation process. Clearly, this aspect of the information may not be available for some time - possibly years. Full risk assessments can then be prepared by all users of the chemicals as the information becomes available.