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What is REACh ? - It is the new European Union regulatory framework controlling the use of chemicals - Registration, Evaluation, Authorisation of Chemicals
- The Regulation came into force on June 1st 2007 with the objective of enhancing the protection of humans and the environment by establishing European-wide, uniform and legal standards.
- REACh replaces earlier legislation related to the notification of existing chemical substances and of new chemical substances.
- REACh has implications primarily for manufacturers and importers of chemical substances. However, it also involves distributors, formulators, users of chemical substances as well as for organisations producing and importing certain types of article.
What is Hart Materials Limited policy in relation to REACh ? - To ensure that the materials we sell are fully compliant with REACh regulations at whatever stage they have developed
- To ensure that our customers are fully informed about the legislation in terms of our responsibilities as their supplier and their own as a Downstream User (DU)
Dr. Tony Hart - Chairman and Managing Director of Hart Materials Limited - states:- “As a Consultant to the Nickel Institute I have, during the last 4 years, gained a good working knowledge of this complex piece of legislation. In the first instance it will ensure that all of the materials sold by my company are fully compliant with the current stage of REACH legislation. To that effect I can now confirm that all relevant materials have now been Pre-Registered before the deadline date of 30th November 2008 and that Hart Materials Limited is actively engaged in the necessary steps for the subsequent stage of the REACh legislation, i.e. Registration. | |  |
As far as our customers are concerned company policy is to keep them informed of the progress that is being made with Registration under REACh since this will involve them in feed-back related to the applications to which Hart Materials’ products are put. My own personal experience has provided an invaluable chain of well informed contacts that can be called upon to provide answers to difficult problems The information provided below is a simple summary of this detailed and complex legislation. It is intended to be a reasonable guide to the main features. Links to official sites are provided to assist those who feel the need for full detailed information. The objective of Hart Materials Limited is to assist customers in relation to this regulation to ensure profitable trading whilst complying fully with the legal requirements of REACh.”
REACh Deadlines For existing chemical substances with EINECS and CAS numbers there is a phase-in period for Registration under REACh from November 30th 2010 until 31st May 2018, depending on the quantity of the product involved and the hazard classification. The full schedule of REACh deadlines is as follows:-
(including Pre-Registration where the deadline has now passed) Legislation came into force: June 1st 2007
Start of Pre-Registration: June 1st 2008
End of Pre-Registration: November 30th 2008
Completion of Registration: November 30th 2010 Substances manufactured or imported in amounts exceeding 1,000 te/yr.
Substances classified as R50 – R53 manufactured or imported in amounts exceeding 100 te/yr
ALL substances classified as CMRs Category 1 and 2 and manufactured or imported in amounts exceeding 1te/yr
Completion of Registration: November 30th 2013 ALL substances manufactured or imported in amounts exceeding 100 te/yr
Completion of Registration November 30th 2018 ALL remaining substances manufactured or imported in amounts exceeding 1 te/yr
Notes - It is illegal to sell in the EU materials that were not Pre-Registered by 30th November 2008
- Materials manufactured or imported in quantities less than 1te/yr are not subject to REACh
- New substances manufactured or imported in quantities more than 1te/yr will require full Registration before they are placed on the market
- CMR is a commonly used acronym for Carcinogenic, Mutagenic, Reprotoxicant
- Customers of Hart Materials Limited will be classed as Downstream Users (DUs) in respect of materials supplied by Hart Materials Limited.
- Similarly Hart Materials Limited is classed as a Downstream User
Comfort for Hart Materials’ customers - A large number of the products sold by Hart Materials Limited are marketed either by Vale Inco Europe Limited or by NOVAMET Specialty Products Corporation - a wholly owned subsidiary of the worldwide Vale Inco organisation. Vale Inco has already Pre-Registered all of its own products and all of the NOVAMET materials and is assuming responsibility for Registration of these products. Vale Inco is acting as the Only Representative for all of Vale Inco’s non-European operations, including those of NOVAMET.
- All of the manufacturers of other products sold by Hart Materials Limited have now confirmed that their products, or the chemicals are used to manufacture their products have all been properly Pre-Registered.
- Many of the products sold by Hart Materials Limited are related to nickel metal and its associated products, for example stainless steel. For many years nickel and nickel-containing materials have been classified as Category 1 Carcinogens; this classification has been confirmed under the recently completed European Union Nickel Risk Assessment and will be the guideline by which these materials are treated under REACh. Regulations for the use of particulate nickel materials should be much less restrictive than they would be if the metal had been subject to a more restrictive classification.
- As Downstream Users, customers of Hart Materials Limited will not be responsible for the process or costs of Registration or – should it be necessary - Authorisation
Useful web-links
Updated February 2009 DISCLAIMER
The information contained in this publication is given in good faith and is believed to be accurate. Hart Materials Limited does not accept any liability or responsibility whatsoever for the accuracy or completeness of this publication and does not make representation or warranty in relation thereto.
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