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REACH - The final deadline may have passed, but there’s no time to relax!

Posted 03/05/2019 by Erich Seger, Product Regulatory Specialist for EIMEA

Erich Seger, our Product Regulatory Specialist for EIMEA about the EU’s REACH Regulation at H.B. Fuller.

Although the third and final registration deadline was on May 31, 2018, that doesn’t mean we can consider REACH (Regulation for Registration, Evaluation, Authorisation and Restriction of Chemicals) to be “completed.” It will continue to affect manufacturers, importers and users of chemicals, which is why, at H.B. Fuller, we are particularly interested in the “use maps” developed by FEICA that can help ensure continuity of supply for important chemicals used in adhesive manufacturing.

How would you describe REACH’s importance?


REACH regulation has had an enormous effect on the chemical industry since it came into force in 2007. The intention is to protect human health and the environment while ensuring a well-functioning internal market. So, chemical companies are obliged to describe the impact of the chemicals they manufacture, and to manage their risks, if they want to continue doing business. As you would expect, the implementation of such regulation followed a step-by-step approach, and the transition period for substance registration ended last May. However, the evaluation of substances has led to numerous regulatory measures, such as restricting the use of hazardous substances or replacing substances in the market with safer chemicals. So, REACH has evolved into more of an ongoing process as it will continue to challenge the industry to ensure safe use of chemicals across the supply chain.

Has REACH been a success so far? What has been achieved?

Yes, it has been very successful. During the registration period, in the first 10 years of REACH, the industry managed to register thousands of substances by working collaboratively in SIEFs (Substance Information Exchange Forums). As a result of this initiative, we have much more available data on chemicals. Also, there is pressure to replace high-risk chemicals with safer alternatives. And there’s more! REACH is now used as a model for chemical regulations and its principles have been adopted in countries outside Europe.

The third deadline has passed, can we relax now?

Not at all! Regardless of regulations, we always need to take actions that ensure our products are safe for the environment, our customers, consumers and our colleagues. So, we are committed to implementing continuous improvement measures in all aspects of environmental health and safety.

Part of these efforts include implementing better external communications about chemicals used in specific formulas. For example, REACH registrants provide safety data sheets that contain much more information than before REACH This extended information is often very technical but needs to be understood by all stakeholders in the supply chain. So, we still have a long way to go as communication improvement using extended safety data sheets has not been fully implemented.

How important is the communication with our suppliers and customers in this regard?

This is crucial. Knowledge about REACH is high across this industry’s supply chain, but amongst formulators and users of chemical products, for example, there is opportunity for training. This is why it’s great to see progress made through partnerships, enabled by industry associations – such as FEICA – and with the support of various adhesive companies, including H.B. Fuller.



What initiatives has FEICA developed to improve communication within the supply chain?

FEICA’s task force on exposure scenarios has developed “use maps” to improve communication and direct information about adhesive use upstream to REACH registrants. Ideally, the registrants would consider these use maps while preparing or updating chemical safety reports under REACH. It is expected that, in reverse, this would improve the quality of downstream information too. The use maps are publicly available on the ECHA website.

What are the main challenges for the industry and, specifically, for an adhesives supplier?

The continuous substance evaluation process under REACH requires all stakeholders in the industry to monitor substance properties and uses. Chemicals considered more dangerous or hazardous need to be phased out and replaced by safer alternatives. For an adhesives company like ours, reformulation of products has to be considered when restrictions or re-classification occurs. The challenge is maintaining, or even improving, product performance. Our regulatory and R&D teams work closely with industry partners to monitor current guidance and adjust H.B. Fuller’s product portfolio accordingly.

In addition, adhesive suppliers are generally considered to be downstream users. REACH limits downstream users to purchasing their raw materials from suppliers in the EU that have registered substances of concern or, alternatively, from suppliers outside the EU that have EU-based representatives that have completed REACH registration on their behalf. This limits the supply of certain raw materials into Europe and we, at H.B. Fuller, use our network of chemical suppliers to address this challenge.

What else does H.B. Fuller do to fulfill its REACH obligations?

We continue to work with adhesive industry associations on local, national and regional levels. This supports the adhesive industry, ensures a level playing field, and goes beyond the pure legal obligations.

At a customer level, we provide regulatory support, including training and seminars that help our customers fulfill their REACH requirements.

 

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