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1) What has to 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 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) When do I have to register by? Companies which already manufacture or import substances into the EU have the opportunity to pre-register their substance in the 1st June - 30th November window 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:
1 June 2013 - 6 years after REACH comes into force:
1 June 2018 - 11 years after REACH comes into force:
Substances which 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 first submitting a completed registration dossier to the ECHA. (Source: REACHReady)
3) What happens if a company does not want to share their 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 (RMM's). The downstream user then submits this document to the ECHA, which if accepted grants them permission to use the substance for uses outside the suppliers 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 (see link below in Where can I find guidance 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 sidestreams). 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 us.
6) Will Infineum be registering their polymers? Polymers do not have to be individually registered under REACH. Rather the constituent monomers and other reactants within the polymers either have to be registered on import, or registered 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? Guidance from REACH covering compilation of a registration dossier identifying uses of the substance and exposure scenarios, including a new "use descriptor" system is not yet complete. Therefore this area cannot be sensibly progressed at this time. When Infineum begins to compose their registration dossiers it is likely that we will contact our downstream users to ensure that we are covering all of the identified uses of our packages.
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 ATC (Additives Technical Committee, the CIA (Chemicals Industry Association in the UK) and CEFIC (European Chemical Industry Council). 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 be offering an only representatives service? Under REACH, any company importing a package will require registrations for all substances in the package. However, REACH allows for 'non-EU manufacturers' to establish an only representative service for their customers. Under this scheme each importer becomes a 'downstream user' and does not need its own registrations, but rather will be covered by the registration held by the only representatives on behalf of the non-EU manufacturer. The guidance around this topic is continually evolving and Infineum is currently investigating the options within this area. When the situation is clearer Infineum will be able to provide more clarity to our customers.
11) Where can I find guidance on REACH? Information on REACH can be found by following the hyperlinks in the
links section of Infineum.com/REACH as well as the Automotive Industry
Guidance which can be found at:
12) I have a question that's not here?
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