REACH (EU Strategy for new chemicals) & Success Service Dr. Andreas Kicherer
Agenda REACH What is it How are Turkish plastic manufacturers affected What help does BASF Success offer What additional Sustainability service is offered by BASF Success
What is REACH? REACH (Registration, Evaluation, Restriction and Authorisation of Chemicals) is the new EU chemicals regulation It applies to all companies manufacturing chemicals in the EU using (handling) chemicals in the EU importing chemicals into the EU The contact company for Turkish suppliers is the importer in the EU
Final situation 2018 approx. 30.000 manufactured and used substances >2.000 Registration > 5.000 Registration of: Production volume Uses Hazard data for 10 t/a: Chemical Safety Reports (CSR) Evaluation Compliance check and examination of testing proposals by the Agency Substance evaluation by competent authorities of MSs Authorisation Authorisation for special uses of CMR 1+2, PBT, vpvb and other substances of similar concern (e. g. endocrine disruptors)
Timelines of REACH 1st of June 2008-30th of Nov. 2008 Entry into force Pre - registration Registration Evaluation >/= 1.000 t/a CMR 1+2 ( >/= 1 t/a ) R50-53 ( >/= 100 t/a ) >/= 100 t/a Registration Evaluation End of Phasein 1.6.2022 >/= 1 t/a Registration Eval. Authorisation / Restriction New Substances.. 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
What is regulated under REACH? All substances as such (e. g. styrene) in preparations (e. g. pigments in masterbatches) in special cases in articles (e. g. phthalates in PVC flooring) >/= 1 t/a per manufacturer/importer and substance
What is not relevant for REACH? Polymers (like polystyrene) Waste Articles (like a joghurt cup) Medicinal products Non-isolated intermediates
Elements of REACH Preregistration Who has the duty to preregister? The manufacturer/ importer must preregister How and where? Electronically at the European Chemicals Agency (ECHA) What? Identity of substance; Identity and contact details of the manufacturer or importer Registration Deadline / tonnage band (>/= 1000, >/= 100, >/= 10, >/= 1 to) Duty? Only if the preregistration is done, the transition periods (2010/2013/2018) are valid; depending on hazard and quantity! Without pre-registration, non further production within the EU or import into the EU from December 2008!
Elements of REACH Registration All preregistered substances benefit from the transitional periods for registration Who has to register, how and where? The manufacturer/ importer must register electronically at the European Chemicals Agency (ECHA) What? >/= 1 t/a technical dossier >/= 10 t/a technical dossier and Chemical Safety Report (if hazardous including exposure and risk assessment) Example: for a substance >/= 1000 t/a with two different uses this may easily be a document with more than 100 pages! (pilot project 2005)
Importers` duties - impact on producers in turkey (1) Who is the importer of a substance (as such or in a preparation) into the EU? The one who goes through customs with the substance What are the duties? The importer has the duty to (pre)register the importer needs data / information For preregistration : identity of the substance (preparation: the identities of the components) imported volumes on substance-base (more or less than 1 t/a)
Importers` duties - impact on producers in Turkey (2) For registration: Data requirements (nr. of tests) physicochemical data (e. g. melting point, densitiy ) toxicity data (e. g. acute toxicity LD 50, skin irritation ) ecotoxicity data (e. g. fish toxicity, bioaccumulation) >/= 1000 >/= 10 >/= 100 No data no market >/= 1 Volume of substance (t/a) Importers have possibilities to get information: Principle of registration in consortia via a lead registrant Principle of mandatory data sharing
Special cases Polymers No duty to register a manufactured or imported polymer Imported polymers: all monomers and other components >/= 2 % and 1 t/a have to be registered This includes e.g. crosslinkers, pigments and colorants, softeners Articles No duty to register a manufactured or imported article (e.g. chair) Duty to register any substance in an article if the substance is >/= 1 t/a and intended to be released (perfume in a smelling eraser) Duty to notify if a substance is identified for authorisation, >/= 1 t/a and >/= 0.1 % in the article (e. g. softener subject to authorisation in PVC flooring)
REACH and Producers in Turkey Wait and see until the importer comes with questions Risk: no preregistration - no data no market Action: communication with / help for importers Proactive approach (sooner or later REACH will be the international standard) Sourcing: BASF products are REACH compliant New chemistry or other sources: check compliance, if necessary registration BASF - Success services
REACH services - an overview Information Assessment of current situation Preregistration Registration - Examination of existing documents such as e. g. safety data sheets - Data gap analysis - Testing - Drawing up of the Chemical Safety Report in its entirety or in part - Chemical hazard assessment - Exposure assessment (through models or measurements) - Risk characterisation Authorisation - Drawing up of authorisation documents - Implementation of a socio-economic analysis
Two Types of Customer Interaction On-demand services (together with BASF products) Direct services to externals (only selected services, e.g. REACH)
What are Main Services Areas within Success? Product Safety/ Chemical Policy, REACH Experimental Toxicology and Ecology Emissions, Ambient Air Concentrations, Environmental Analysis Waste Management Soil Protection and Ground Water Pollution Wastewater Energy Generation, Energy Conservation Emergency Response Distribution Safety Authorizations, Statutory Regulations Safety, Health at the Workplace Eco-Efficiency
SuccESS provides a solution in the context of wastewater situation A customer from the tannery industry is not able to comply with legislative requirements because his wastewater treatment plant does not meet the technical standards Service from Success: On-site current state analysis Suggestions for further improvement and measures to be taken Customer training in BASF s wastewater laboratory The customer obtained an independent and competent assessment of his wastewater situation. The report on findings provided the basis for further steps. Update 31.07.06
CONTACT INFORMATION BASF Aktiengesellschaft Success-Info-Point D - 67056 Ludwigshafen Telephone: +49 621 60 79777 Fax: +49 621 60 6679777 Email: success-team@basf.com http://www.basf.de/reach