Masterbatch and Technical Compounds Group Issues REACH Statement

Position of Members of the BPF Masterbatch and Technical Compounds Group with regards to the REACH Regulation

What is REACH

REACH, regulation (EC) No. 1907/2006, is a European Union regulation concerning the Registration, Evaluation, Authorisation and restriction of Chemicals. The legislation entered into force on 1st June 2007 to streamline and improve the former legislative framework on chemicals of the European Union (EU). The key aim of its implementation is to protect human health and the environment from the risks arising from the use of chemicals. Under REACH, the responsibility for demonstrating the safe use of chemical substances will be transferred from regulators to industry.

For further information please visit, http://echa.europa.eu/home_en.asp

Status of Masterbatch and Technical Compounds Suppliers under REACH

Under REACH, Compounds and Masterbatches are considered as preparations - a mixture of substances with different chemical identity.

As downstream users of substances and preparations, Members of the BPF Masterbatch and Technical Compounds Group are working with their raw material suppliers and taking all necessary measures to ensure continued availability and supply of all substances used in their products.

PRE-REGISTRATION

Preparations do not require pre-registration.

If however a company manufactures or imports a preparation into the EU market they will have to ensure that all components of the preparation are pre-registered or registered. Without the pre-registration or registration of single substances, further sale of the preparation will not be possible.

The pre-registration period ended on November 30th 2008. Late pre-registration is however permitted under certain circumstances if a company first imports a chemical after this date.

There is no legal requirement for pre-registration numbers to be provided down the supply chain.

REGISTRATION

Full registration is now under way with a timetable dependant on tonnage manufactured / imported and / or hazard profile of the substance. Preparations do not require registration. Some chemicals do not need to be registered until 2018, and those that are manufactured or imported in quantities of less than 1 tonne per year are exempt from registration.

BPF Masterbatch & Technical Compounds Group Members continue to maintain contact with both suppliers and customers regarding communication of information and collection of data as necessary.

Due to the lengthy phase in period this will be a continually evolving situation where BPF Masterbatch & Technical Compounds Group Members shall commit to updating their customers in a timely manner as soon as any new information is obtained in the supply chain.

SUPPLY CHAIN COMMUNICATION

Safety Data Sheets, intended Application and Exposure Scenarios

The REACH regulation includes criteria for material safety data sheets (MSDS) for hazardous products. The MSDS will remain the central element in the communication between supplier and customer on security issues and uses for substances as well as for preparations.

In line with that, the MSDS has to be supplemented by a system in which the exposure of humans and the environment for the use of the substance / preparation is described – Exposure Scenarios.

Material Safety Data Sheets are being modified to reflect the requirements for layout and content under REACH and will continue to be updated as necessary.

It should be noted however that many masterbatch materials are not considered hazardous and therefore are not required to be supplied with a Material Safety Data Sheet, although it is industry practice to do so. It is a legal requirement for hazardous constituents to be declared on an MSDS. However compositional information (including registration numbers) is not mandatory for non hazardous ingredients that may be present in a mixure.

Plastics Exposure Scenario Team

The Plastics Exposure Scenario Team (PEST), which represents the plastic supply chain and includes the most important associations representing additive manufacturers/importers, compounders, masterbatchers, plastics converters and plastics producers, fully supports plastics downstream users;

• to maximize the chances that their uses will be covered in the registration dossiers by reporting their uses, in line with Article 37(2) to their suppliers, before 1 December 2009.
• to confirm that their uses will be assessed.

The BPF and its Masterbatch and Technical Compounds Group are participating in PEST and fully support this initiative.

SUBSTANCES OF VERY HIGH CONCERN (SVHC)

Substances that are included in the Candidate List have been identified as Substances of Very High Concern (SVHC). Substances on the Candidate List may subsequently become subject to authorisation by decision of the European Commission.

Members of the BPF Masterbatch and Technical Compounds Group will inform you if their products contain any substances classified as SVHC. Such materials would already be declared in section 3 of the Material Safety Data Sheet due to their hazardous nature. This is not a new obligation under REACH.

The candidate list is regularly updated, and thus Members will need to re-evaluate the presence of SVHC each time a new update is published. Please contact individual Member firms for further information.

List of Substances of Very High Concern: http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp

REACH Useful Links

European Chemicals Agency (ECHA); http://echa.europa.eu/home_en.asp

 BPF REACH Toolbox (BPF Members only); http://www.bpf.co.uk/REACH/REACH_Plastics_Toolbox.aspx

EuPC REACH Club; http://www.eupcservices.org/services/helpdesk

Plastics Exposure Scenario Team – PEST; http://pestpublic.plastics.net/public/

UK Health and Safety Executive: http://www.hse.gov.uk/reach

Contact Information

For further information please contact Sarah Plant, Senior Executive at the British Plastics Federation:
Tel: +44(0)207 457 5000 | Fax: +44(0)207 457 5045 | Email: splant@bpf.co.uk