Work is well underway and on track to meet the May 2018 registration deadline
In June 2007, the European Union’s legislation on the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) entered in to force.
REACH imposes many obligations upon chemical companies who do business in the EU, especially those who manufacture within the EU or import chemicals in to the EU. These obligations are being phased in over an 11 year period. Afton started preparing for REACH in 2003 and has hired several new staff to augment its efforts in properly preparing for the various REACH regulatory deadlines.
Afton successfully registered the applicable chemicals before the November 2010 and May 2013 regulatory deadlines. Afton is now compiling and submitting its registration dossiers for the lower volume chemicals.
Afton has delivered numerous presentations on REACH to its customers, employees and at industry conferences. We are involved in several industry consortia and in many Substance Information Exchange Forums (SIEFs). We also actively help our customers meet their REACH obligations for the chemicals they purchase from Afton.
Declarations of REACH Conformance (DRCs) are provided to Afton’s customers free of charge. This is their evidence that the products that they buy from Afton are in conformance with REACH. Many challenges will be faced by the chemical industry in complying with REACH but Afton is well placed to meet these challenges.
For further information on REACH please contact EHS3 Product Stewardship Group on +1-804-788-5800 or email.
REACH stands for the Registration, Evaluation, Authorization and Restriction of Chemicals. The REACH Regulation entered into force on 1st June 2007 to streamline and improve the former legislative framework for chemicals in the European Union. REACH requires that all chemical substances that are manufactured or imported into the EU at ≥ 1MT be registered. The obligation for carrying out the registrations falls on EU manufacturers, importers and Only Representatives. The European Chemicals Agency (ECHA) based in Finland is the regulatory body which manages the technical and administrative aspects of REACH.
During the pre-registration phase of REACH which lasted from 1 June to 1 December 2008, Afton successfully pre-registered over 300 existing substances. This was followed by the full registrations of the necessary high volume (> 1,000 MT) substances which had a deadline of November 30, 2010 and then the 100 - 1,000 MT substances before May 31, 2013. Afton was the lead registrant for several of these substances. Afton is now working on compiling dossiers for substances in the 1 – 100 MT category that have a registration deadline of May 31, 2018.
SVHCs - Substances of Very High Concern
One of the goals of REACH is to restrict the commerce of high hazard chemicals through the Authorization process. An EU Member State or ECHA must first nominate a high hazard chemical to the Substances of Very High Concern (SVHC) list before a substance would be considered for Authorization. In general a substance might be considered for addition to the SVHC list if it is a CMR (carcinogen, mutagen and/or reproductive toxin), PBT (persistent, bioaccumulative and toxic), vPvB (very persistent, very bioaccumulative) and/or would otherwise pose serious effects to human health or the environment. If a substance is nominated, the REACH regulation has a provision for industry/public response prior to addition to the SVHC list.
Afton closely monitors the Candidate list and ECHA’s recommendations for Authorization. The appearance of a substance on the Candidate list does not automatically mean that the substance will eventually be listed on Annex XIV, the list of substances subject to Authorization. Should a product contain a Candidate listed substance at >0.1%, Afton will work with suppliers and customers to assess the implications of this listing and address any customer concerns.
As a customer of Afton, you or your customers may be importing Afton’s products into the EU either as a package or as a finished fluid containing an Afton component. Afton’s desire is to ensure that all of our downstream customers are compliant with the REACH regulation. Afton is happy to provide a conformance option to you and your customers by serving as your Only Representative (OR). As your OR, Afton accepts the responsibility of ensuring that your Afton purchased substances are registered.
In order to ensure your company’s REACH conformance through Afton’s OR services, there is an obligation for you to communicate your annual import volumes per importer. This ensures that Afton registers within the correct tonnage band as our customers’ import volumes must be summed into a single registration per substance. Once updated volume/importer information is received, Afton will provide a Declaration of REACH Conformity (DRC) for each Afton product you (or your customers) are importing into the EU. The DRC will serve as evidence that the products purchased from Afton are in conformance with REACH, as long as the “Conditions of Issue” stated on the DRC are followed. Please contact us before import if you are interested in this option.
Afton remains committed to ensuring that the substances in its products conform to REACH and helping its customers through the obligations and implications of this legislation. Should you have any questions please contact your Afton Chemical representative or email.