Facts

Messages

-Although the first REACH registration deadline has passed some details need further clarification.

-Baerlocher is carefully observing the developments in these REACH interpretations.

-Baerlocher is committed in meeting the legal obligations under REACH and have started preparing for it (since 2003)

-They have ensured that all of their manufactured or imported products entered the pre-registration to ensure the transition periods.

-Baerlocher is in close contact with their suppliers to ensure that the purchased materials are pre-registered and registered as well.

-It is their intention to register their products as much as possible. If certain substances will be phased out, they will inform the customers in due time.

-Identified use: has to be communicated from the customers to the suppliers to prepare the necessary risk assessments accordingly.

-If customers have special applications, which should be considered in the exposure scenarios, an early contact would be helpful.

-Baerlocher is an active member of several consortia to prepare the necessary registration dossiers.


REACH deadlines

-Pre-registration (1st June - 1st Dec.2008)

-Registration (1st Dec.2010) for substances:
manufactured/imported >1000 t/y
CMR cat. 1 and 2 (>1 t/y) (carcinogenic, mutagenic, toxic to reproduction) classified with H400/H410 (>100 t/y) (very toxic to aquatic organisms)

-Registration (1st June 2013) for substances:
manufactured/imported >100 t/y

-Registration (1st June 2018) for substances:
manufactured/imported >1 t/y


Stabilizer systems under REACH

Lead

-all lead substances manufactured or imported have been successfully registered;
-lead substances will require authorisation for sales within the EU;
-sunset date unknown yet (expected between 2010 and 2015);
-will probably require registration only for sales outside the EU;
-authorisation after sunset date unlikely to be granted because a substitution plan (Vinyl 2010) exists and no socio-economic benefit;
-it is expected that annex XIV will be used as a black list by certain parties as soon as published and give additional pressure on substitution.

Tin

-many tin substances have already been registered, some require registration 2013 or 2018;
-several substances will require authorisation;
-risk assessment showed no concern in rigid PVC applications;
-for the time being the EU Commission/member states are considering restrictions/use bans for certain applications; (decision expected in autumn 2008)
-food contact applications are not affected by REACH.

Ca-based

-only registration and evaluation is required.