 |
| |
European Chemicals Legislation: REACH |
BASF gave REACH a very high priority, as such we followed and contributed to the legislative process since the beginning of REACH. Although REACH has since been adopted, BASF continues its effort in this regard, for example through active involvement in several European Commission REACH Implementation Projects (RIPs).
|
 |
What is BASF doing to get prepared for REACH?
|
 |
Will BASF pre-register and register the substances of the product I am using?
|
 |
Do I need to ensure, that my uses are covered in the registration dossier?
|
 |
What happens, if my use is not covered by the registration?
|
|
|
|
What is BASF doing to get prepared for REACH?
In order to ensure that the whole BASF group is well prepared for REACH, the implementation work was started in 2004.
The preparation work of BASF mainly follows the recommendations of Cefic / VCI with respect to BASF specific requirements. This includes the establishment of a substance inventory, gathering use and exposure information and collecting available information on intrinsic properties.
|
|
 |
|
Will BASF pre-register and register the substances of the product I am using?
BASF intends to pre-register all substances manufactured in/or imported into the European Union.
Through the pre-registration, BASF endeavors to avoid any unnecessary disruption in the marketing and supply of such substances. The full registration of any relevant substances will follow, in accordance with the transitional provisions of the regulation, in the years 2010 to 2018.
As a downstream user, BASF will work with its suppliers to ensure that key raw materials will be supported and that our manufacturing processes will not be affected.
Whereas the pre-registration is an activity of each individual supplier, the registration work shall be a joint activity of all registrants of one particular substance. This specifically includes the exchange of available study information requested by REACH.
In line with the core statements/goals of the BASF strategy, “Help our customers to be more successful!”, the product portfolio of our company is subject to a steady optimization due to the expectations and needs of our customers. Since the registration time frame will last until 2018, depending on the volume manufactured and imported, forward-looking statements on registration for such a long time period are not expedient.
|
|
|
|
Do I need to ensure, that my uses are covered in the registration dossier?
The risk assessment of uses plays a central role in the REACH concept and will require the exchange of information between supplier and downstream user.
Risk assessments of uses under REACH are only required for products containing substances classified as hazardous and listed in the safety data sheet. Use information is not required for products, which are not classified as hazardous or for substances that are produced with less than 10 tons per year.
For the time being BASF and industrial associations support the development (e.g. in RIPs) of use and exposure categories in order to harmonize/simplify the assessment of use specific exposures, to facilitate the communication and to reduce the overall workload in the supply chain. However, present questionnaires are limited with respect to the complete gathering of information. To avoid double work for customers BASF is preparing technical solutions to make sure that all information needed from its customers will be requested in good time.
BASF recommends to wait for the use and exposure information included in the new extended safety data sheet.
|
|
|
|
What happens, if my use is not covered by the registration?
BASF products are used by our customers in diverse applications. We aim to support this broad use spectrum of our products.
Usually, a substance registration will lead to a new revised safety data sheet of the derivative downstream product. Only when the downstream user receives this new safety data sheet including the registration number, will the exposure scenario-related obligations apply.
In the case that a certain use is not covered by the exposure scenarios, the downstream user has 12 months to make this use known to the supplier (or 6 months for writing their own Chemical Safety Report). During this time, it is legal to continue the use (ref. Art. 37.3).
Exposure scenarios need not be developed for products, which do not contain hazardous substances (ref. Annex I, 0.6) or for substances that are produced with less than 10 tons per year (ref. Art. 10.1). In these cases, use information is not required.
|
|
|
|
|
|
|
