Stratgie Marketing oprationnel Dpartement Arosols

1
REACH
2
What is REACH?
Registration, Evaluation and Authorization of
CHemicals
850 pages

• European Regulation
• Available in each member states
• Immediately available

3
REACHs aims
Improve knowledge and expertise of chemicals
? Improvement of the PROTECTION of Health
Environment ? Re-enforce TRANSPARENCY ? Enforce
INNOVATION and COMPETITIVENESS in the EU ?
Promote laboratory tests without animals
NO DATA, NO MARKET
4
REACH
DANGERS
RISKS
Risks measurement
Exposition during the use of products
PRODUCERS IMPORTERS
MEMBER STATES
RESPONSABILITIES
5
Players in REACH

• Producer
• producer EU
• Importer (only representative)

DOWN - properties - risks
management
Downstream User Formulator and/or Fillers
Distributor
Distributor
Downstream User industrials Producers of
articles or pieces
UP information about uses
User
6
The scope of REACH

• Substances

Substances in preparations
Very High concerned substances in articles
Substances in article and released into the
atmosphere during the use
Ex swimming-pool liners
Ex perfumed candles
7
Timing
Registration
1 -100 t/y
Pre-registrated substances list
100-1000 t/y

• 1000 t/y
• CMR 12 gt 1 t/y
• R50-53 gt 100 t/y

Pre-registration 6 months
Exchange Forum (SIEF)
31/05/2013
31/05/2018
1/06/2007
1/06/2008 to 30/11/2008
30/11/2010
1/01/2009
8
Your role

• If your supplier is an European producer
• Check he intends to make the pre-registration
  before 30/11/2008
• ?If not, no more product on 1/01/2009
• Make sure he intends to make the registration
• ?If not, no more product depending the
  registration timetable (end-2010, mid-2013 or
  mid-2018)
• Communicate him your uses so he considers it in
  his risks management measures
• If your supplier is not the producer, you have to
  make sure that your supplier make the work
  regarding his European producer.

NO DATA, NO MARKET
9
Your role

• If your supplier is not an European producer
• Make sure he is aware of REACH
• Ask him how he will make the registration
• ? only representative ?
• ? or do you want to make the registration
  yourself ?
• ? if not, no more product on 1/01/2009

NO DATA, NO MARKET
10
Downstream User obligations

• Make sure that all your substances are
  pre-registrated 1/01/2009
• ? If not, you have to communicate your
  substances immediately at the European Chemical
  Agency (ECHA)
• Give your supplier your uses and your actual risk
  management
• ? Mode
• ? Employees exposure
• Apply the Risks Management Measures (RMM)
  recommended by your supplier (timing 12 months
  after you get the new MSDS and exposure scenario
  if they are join to the MSDS)
• If your use is not taken into account or if the
  RMM are not available in your activity, you have
  to make your own risks evaluation and communicate
  it to the agency

http//echa.europa.eu/
11
REACH in the DEHON group
- Exposure scenario for preparations - On-going
of substances
RD
Formulations
Exchanges
Commercial Team
Purchaser
Plant manager
Uses in our plant
Exchanges
12
How is DEHON organized?
European
13
Charges Fees
in
14
Test costs
in
Maximum costs

• non-direct costs 50 of test costs
• Experts
• Participation to exchange forums

15
Your  To Do  list

• Find your position regarding REACH
• Make the inventory of your substances
• Collect available information
• Prepare to communicate your uses to your
  suppliers
• Make sure your suppliers scenario is in
  accordance with your use
• Apply Risks Management Measures
• ? Feel free to contact Avantec if you need help
  in some of these actions

16
Your REACH-Contact

• Your  REACH-contact  in Avantec is
• Virginie FOURNEAU
• 334.72.28.14.66
• vfourneau_at_avantec.dehon.com