Embed Size (px)
Citation preview
Customer information 2016
REACH!We will be glad to advise you.
We are ‘REACH-
Compliant’!
Duties of importers (and manufacturers) of substances as registrants
Implementation within the LEHVOSS Group
Preregistration of phase-in substances Several preregistrations completed; preregistration is carried out for new substances with market potential (expected > 1 t/a)
Registration of phase-in substances Diverse registrations carried out, others are planned
Registration of non-phase-in substances prior to import/manufacture
One non-phase-in substance registration already carried out
Transfer of the obligation to register to the only representative, if appropriate
Use of only representatives, documentation and regular examination of the only representative status
Ongoing inspection of the import/manufacturing quantities Monitoring of the import quantities with a modern substance-volume tracking IT system
Forwarding of safety data sheets compliant with REACH/CLP Creation and forwarding of safety data sheets compliant with REACH/CLP (incl. information on SVHC status of a substance if appropriate)
Additionally: l we use internal and external networks to regularly exchange experience (e.g. VCI Regionalverband Nord [northern regional association of the German Chemical Industry], REACH Hamburg network (http://www.reach-hamburg.de/).l we have developed a standard operating procedure to ensure compliance with the requirements and the marketability of the products.
As a customer with us, you can be sure that all requirements will be met: as a registrant, we are actively involved in the REACH process.
2
We will be pleased to advise
you on your REACH tasks!
An overview of REACH implementation: the tasks within the supply chain
3
4
We will be pleased to advise
you on your REACH tasks!
As a downstream user, you comply with the statutory REACH requirements if you proceed as follows:
Tasks of downstream users
Examination of safety data sheets for consistency of the information
Determination and forwarding of identified uses for substances/products in accordance with Use Descriptor System
Examination of the identified uses (Annex of the safety data sheet)
If you as a downstream user establish that a registrant has not taken account of your application in the registration or does not wish to notify the downstream user of the application in order to maintain company secrecy, the downstream user may have to submit an independent use registration, detailing the hazard potential for humans and the environment together with safety precautions.
5
The story continues even
after 2018!
The requirements of the REACH regulation do not come to an end after 2018:
REACH process ... ... after 31 May 2018
Preregistration is only possible up until 31 May 2017, ceases afterwards
Registration Substances > 1t/a, which are to be newly imported/produced have to be registered prior to import/being placed on the market.
Tonnage-dependent registration deadlines cease to apply
Adaptation of existing registrations registration dossiers must be adapted if there are any changes in the annual tonnages and changes/additions to the identified uses prior to their further import/being placed on the market
Therefore:Think about supply chain communication at an early stage.Consult us so that we can jointly identify and implement all REACH requirements in time.
6
REACH: Terminology /
Q&A
Terminology: An overview of the key aspects (I)
REACH term Explanatory note
REACH Registration, Evaluation, Authorisation and Restriction of Chemicals, EU Regulation 1907/2006/EChttp://echa.europa.eu/web/guest/regulations/reach/
Phase-in substance The substance is listed in the European Inventory of Existing Commercial Chemical Substances (EINECS). EINECS is the directory of substances that were on the market before 1981. It contains more than 100,000 existing substances.
The substance was manufactured in the EU, but not placed on the market by the manufacturer or importer before the entry into force of REACH (for example substances used within a company).
The substance was classified as a polymer until the start of the nineties (entry into force of the 7th amending directive 67/548/EEC) and counted as registered; however, it does not comply with the definition of a polymer according to the REACH Regulation. Certain emulsifiers and prepolymers, for example, fall into this category. These substances are also termed „No-Longer Polymers“ (NLP) and are contained in the NLP list.
Non-phase-in substance Does not meet any of the criteria under ‘Phase-in substance’
7
REACH: Terminology /
Q&A
Terminology: An overview of the key aspects (II)
REACH term Explanatory note
Only representative(Article 8 REACH regulation)
A natural or legal person established outside the Community who manufactures a substance on its own, in mixtures or in articles, formulates an M3 mixture or produces an article that is imported into the Community may by mutual agree-ment appoint a natural or legal person established in the Community to fulfil, as his only representative, the obligations on importers under this Title.The representative shall also comply with all other obligations of importers under this Regulation. To this end, he shall have a sufficient background in the practical handling of substances and the information related to them and, without prejudice to Article 36, shall keep available and up-to-date information on quantities imported and customers sold to, as well as information on the supply of the latest update of the safety data sheet referred to in Article 31.If a representative is appointed in accordance with paragraphs 1 and 2, the non-Community manufacturer shall inform the importer(s) within the same supply chain of the appointment. These importers shall be regarded as downstream users for the purposes of this Regulation.
REACH objective REACH unites numerous legal documents on EU chemical legislation that existed alongside each other and sup-plements them with new aspects. The aim of the regulation is to improve the information that exists on chemical substances manufactured within and imported into the EU. It additionally aims to reduce the risks associated with the use of chemical substances.
ECHA(www.echa.eu)
European Chemicals Agency headquartered in Helsinki (Finland); its responsibilities include monitoring the implementation of REACH at European level as well as continuing to develop the process (guidelines, definition of substances of very high concern (SVHC), etc.).
8
REACH: Terminology /
Q&A
Terminology: An overview of the key aspects (III)
REACH term Explanatory note
SVHC Substances of very high concern are substances with properties that are carcinogenic, mutagenic or toxic to reproduc-tion, hormonally active, allergenic, particularly environmentally hazardous; they are placed on the “candidate list” as a first step of the authorization procedure in accordance with REACH. http://echa.europa.eu/de/candidate-list-table
Use-Descriptor-System Standard descriptors that provide descriptions of uses combined with one another and the exposure scenarios associated with them; they consist of 5 categories to be combined:
SU (Sector of Use) / PC (Product Category) / PROC (Process Category) / ERC (Environmental Release Category) / AC (Article Category). The Use Descriptor System must be used for the standard description of identified applica-tions in the supply chain. http://echa.europa.eu/documents/10162/13632/use_descriptor_system_en.pdf
CLP stands for ‘Classification, Labelling and Packaging’, European Regulation 1272/2008/EC which governs the clas-sification and marking of hazardous substances and mixtures. http://echa.europa.eu/web/guest/regulations/clp
You will also find additional questions and answers (Q&A) on details of the REACH process on the ECHA website athttp://echa.europa.eu/support/qas-support/qas
9
Your REACH contacts
We’re there at your service!
Lehmann&Voss&Co.REACH-Contact Person
Phone E-mail
LUVOCOM® Dr. Heiko Thoms +49 40 44 197 454 [email protected]
LUVATOL®
Thomas Fehling +49 40 44 197 406 [email protected]
LUVOBATCH®
Marion Henkens +49 40 44 197 409 [email protected]
LUVOMAXX®
Dr. Knud Schlotfeld +49 40 44 197 419 [email protected]
MAGNESIA Andreas Gerber +49 40 44 197 244 [email protected]
OBERFLÄCHENTECHNIK Dr. Knud Schlotfeld +49 40 44 197 419 REACH.Oberflaechentechnik@
lehvoss.de
KOSMETIKAxel Kirchniawy +49 40 44 197 251 [email protected]
FILTRATION Wolfgang Krug +49 40 44 197 249 [email protected]
SubsidiariesREACH-Contact Person
Phone E-mail
LEHVOSS UK Ltd. Ivan Pennington +44 1260 291 000 [email protected]
LEHVOSS France S.a.r.l Frédéric Porcher +33 237 430 551 [email protected]
LEHVOSS Italia S.r.l Maurizio Rosso +39 02 96 44 64 704 [email protected]
Auer-Remy GmbHDr. Knud Schlotfeld +49 40 44 197 419 [email protected]
Coordination and control of the implementation of REACH is the task of our service group “Safety and Environmental Protection” under the management of Dr. Heiko ThomsPhone +49 40 44 197 454, E-Mail: [email protected]
www.lehvoss.com
Lehmann&Voss&Co. KG
Alsterufer 1920354 HamburgTelefon: +49 (0)40 44197-0Telefax: +49 (0)40 44197-219E-Mail: [email protected] www.lehvoss.com
