“The time could not have been chosen better,” Alexander Dangis, managing director of the European Plastics Converters Association (EuPC, Brussels / Belgium; www.eupc.org), said at the opening of the “2nd Conference on REACH – Registration, Evaluation and Authorisation of Chemicals” on 14 December 2005 in Brussels. Only the previous day, the EU Council of Ministers had passed the bill on REACH, but not without making a number of changes compared with the version approved by the European Parliament on 17 November. With the vote fresh in mind, the conference focused its attention on the effect of the legislation on compounders, masterbatch producers and recyclers.

Under REACH, all manufactured and imported substances with an annual consumption of more than one tonne must be registered. If usage exceeds 100 t, they also must be toxicologically evaluated, and if deemed to be hazardous, their use must be authorised. As REACH will be a regulation rather than a directive, it will apply immediately in all EU member countries as soon as it comes into force and will not have to be approved by the national parliaments.

Effects on compounders and recyclers
The new regulation will have a profound effect on the way safety documentation is carried out, which is one reason why chemical producers have complained about REACH´s bureacratic nature. Compounders and masterbatch manufacturers receive Safety Data Sheets (SDS) from their raw materials suppliers. When they convert raw materials into substances, they have to compile an SDS for each. In future, the data must be compiled jointly by the raw material manufacturer, compounder and downstream user (converter). The required cooperation can become a problem when the compounder, for example, uses a substance for a purpose not intended by the raw material manufacturer. The substance could possibly have to be registered at the compounder´s own cost.

REACH foresees that compounders can use so-called “Generic SDS” (standardised safety data sheets for a particular branch of industry), which the Sector Group in the EuPC – European Thermoplastic Independent Compounders (ETHIC, Brussels / Belgium; www.ethiccompounds.org) – is preparing. “Being involved in the production of the generic SDS also gives the compounders a high level of confidentiality against subsequent, undesired disclosure of their formulations,” according to Walter Claes, the EuPC´s health, safety and environment director.

Companies that recycle post-consumer waste appear to have been given a raw deal, as at present there is no generic SDS for waste product recycling. As waste has been excluded from REACH, how can a recycler compile an SDS for a certain substance? The problem has been underestimated by the European authorities, at least as far as the plastics industry is concerned. The good news, however, is that the European Plastics Recyclers Association (EuPR, Brussels / Belgium; www.eupr.org) will endeavour to produce the necessary generic SDS fairly soon.

If everything goes as planned, the EU regulation will take effect in spring 2007. There will then be a period of 18 months during which the manufacturers and importers of chemicals (including all additives and fillers) must pre-register their substances. It will be interesting to see how this pre-registration procedure actually works. It is not likely that the REACH agency will take up its duties before 2008, probably in Helsinki. Nevertheless, Walter Claes offers this advice: “A good way of preparing for REACH is to draw up a list of all the substances used by the company, together with the annual consumption volumes, manufacturers, customers and importers up to the end of 2006.”

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Charts from the Claes presentation with REACH checklists PDF-Dokument (307 KB)