1) What must be registered?
REACH applies to substances; a "substance" is a chemical element or a compound. However, the REACH definition also includes complex substances such as reaction and distillation products. Companies within the European Union (EU) manufacturing or importing substances at above 1 tonne per year are required under REACH to register that substance. Companies importing mixtures into the EU must ensure that all substances in the mixture (over 1 tonne per year) are covered by a registration.
2) By when do I have to register?
Companies that already manufacture or import substances into the EU had the opportunity to pre-register their substances between 1st June and 30th November 2008 to keep substances on the market, in order to take advantage of the extended registration deadlines:
30 November 2010 - 3.5 years after REACH comes into force:
- >=1000 tonnes/year;
- substances classified as carcinogenic; mutagenic or toxic to reproduction (categories 1&2) above 1 tonne;
- substances classified as 'very toxic to aquatic organisms and may cause long-term adverse effects in the aquatic environment' (R50-53) above 100 tonnes
1 June 2013 - 6 years after REACH comes into force:
1 June 2018 - 11 years after REACH comes into force:
Substances that are not pre-registered by the respective manufacturer/importer are not allowed to be manufactured in, or imported into, the EU after 1st December 2008, without the manufacturer/importer first submitting a completed registration dossier to the ECHA. (Source: REACHReady)
3) What happens if a company does not want to share its use with the supplier?
If a downstream user has a proprietorial use, it is possible for them to generate a `downstream user Chemical Safety Report (CSR)’ which covers their use and generates the appropriate exposure scenario, including risk management measures (RMMs). The downstream user then submits this document to the ECHA, which, if accepted, grants them permission to use the substance for uses outside the supplier’s CSR and Exposure Scenarios.
4) Do I need to register substances imported in a "wet" engine or transmission?
According to the Automotive Industry Guidance v.2 on REACH: Preparations such as, but not limited to: brake, transmission, and steering fluids, greases, and lubricants that are in or on automotive articles, are integral to the function of those articles and are therefore considered to be an integral part of the article. They would, therefore, NOT require pre-registration and registration if contained in or on imported articles. These same substances in preparations, however, require pre-registration and registration if imported on their own’.
5) Will Infineum pre-register and register their substances?
Infineum has invested considerable time in ensuring that we have identified the substances we import and manufacture (including intermediates and side-streams). All necessary pre-registration and registrations will be undertaken to ensure that there is no business disruption for ourselves or our customers. Infineum has also requested information from our suppliers to ensure that they are planning to pre-register the substances they supply to us.
6) Will Infineum be registering their polymers?
Polymers are not required to be individually registered under REACH. Rather, the constituent monomers and other reactants within the polymers must be either registered on import or up the supply chain. Infineum has identified all of the monomers and other reactants in its polymers and will ensure that each of them is registered for REACH at the appropriate time.
7) Will I have to communicate with Infineum about my use?
Following industry recommended processes, Infineum have been working within our own and with related downstream user trade associations to define a list of applications that our products are used for. In this way we expect to have captured the majority of downstream uses so that our customers using products in intended ways can feel confident that their use will be covered within the REACH registrations of the constituent substances. See the section titled Registration of Product Uses for further information about product uses and supply chain communication requirements.
8) Will Infineum provide information to suppliers about uses of purchased materials?
Infineum is committed to working closely with our suppliers to ensure that Infineum's uses are covered in our suppliers’ Chemical Safety Reports. Infineum intends to provide information to suppliers on our intended uses when the guidance on the use descriptor system is available and in good time for preparation of registration dossiers.
9) Is Infineum talking to other companies in the same industry about REACH?
Infineum is involved with organisations such as Additives Technical Committee (ATC), the Chemicals Industry Association (CIA) in the UK and European Chemical Industry Council (CEFIC). Infineum also has regular contact with competent authorities to ensure our interpretations are in line with regulators’ and to work jointly on matters of mutual concern.
10) Will Infineum offer an only representatives service?
Yes. Infineum UK Limited is appointed as Only Representative for Infineum's non-EU-based manufacturing affiliates. Customers purchasing from Infineum outside the EU and exporting to Europe should contact Only.Representatives@Infineum.com or their regular sales contact for information on how to utilise this service.
11) Where can I find guidance on REACH?
Full REACH guidance documentation is available via the European Chemicals Agency (ECHA) web site. General information about REACH and its impact may be found at Infineum.com/REACH. More specific information related to products that you buy from Infineum can be obtained by contacting REACH@Infineum.com.
12) If my question is not listed here?
If you have a question concerning the specific impact of REACH on Infineum products, please contact your sales or procurement representative, or e-mail REACH@Infineum.com.