reach implemantaion for an import/export company · import/export company. company presentation ......
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REACH REACH IMPLEMENTAION IMPLEMENTAION
BY ANBY AN IMPORT/EXPORT IMPORT/EXPORT
COMPANYCOMPANY
COMPANY PRESENTATIONCOMPANY PRESENTATION
MASSO business is focussed mainly in MASSO business is focussed mainly in IMPORT of chemical products for IMPORT of chemical products for several sectors of use.several sectors of use.Our Headquarters are located in Our Headquarters are located in BARCELONA , but we have 4 additional BARCELONA , but we have 4 additional European offices in FRANCE, POLAND European offices in FRANCE, POLAND ,CZECH REPUBLIC , HUNGARY, and 3 ,CZECH REPUBLIC , HUNGARY, and 3 more in CHINA, INDIA & DUBAI.more in CHINA, INDIA & DUBAI.We work with more than 100 different We work with more than 100 different
countries , most of them located countries , most of them located outside Europe.outside Europe.
BARCELONA
39.000 m2
WarehouseFormulation plantR+D Quality Control
PRODUCTION
www.cqmasso.com
CASTELLON (Ceramic Department)
19.700 m2
22.000 Tonnes BulkCapacity
Logistics
www.cqmasso.com
WHERE ARE WE?WHERE ARE WE?
COSMETICS
ActivesAesthetic modifiersEmollientsEmulsifiersFilm FormersHumectants PreservativesSolubilisersSurfactants Thickeners
www.cqm.es/[email protected]
ENVIRONMENTAL HEALTH
& CLEANING
PRODUCTS FOR ENVIRONMENTAL HEALTH.
Biocides for pest control in urban environments: insecticides, rodenticides, disinfectants, traps and application equipment.
FORMULATED PRODUCTS AND ACTIVEINGREDIENTS FOR HOUSEHOLD, INDUSTRIAL & INSTITUTIONAL CLEANING
Cleaners, Antioxidants, Optical brighteners , Rheological modifiers , biocides for Household use, mass market products
www.massoambiental.com www.massoconsumo.com
AGROCHEMICALS
The Agro Division of Comercial Química Massó, S.A. formulates and distributes to the Spanish & Italian & Portuguese market a wide range of Crop protection products.Most of these products come from foreign companies, some of them being among the most important International Companies in the Crop Protection sector
www.massoagro.com www.massogarden.comE_mail:
www.cqm.es/fcr
Food ingredients and additives for food, dietetics and functional foods.
•Probiotics & Prebiotics•Peptides•Lecithin•Spices•Functional Ingredients for Meat Products•Seasonings and Decorative Herbs•Flavours•Essential Oils and Fragance Fine Chemicals•Gibberellic acid•Tannins and Oak Extracts• Enzymes•Omega-3 and 6 fatty ac.•Vegetal Extracts•Stabilisers (Guar and Xanthan gum, Sodium Alginate…)•Sweetners (Saccharine)•Milk proteins
FOOD
E_mail: www.cqmasso.com/food
POLYMERS
POLYPROPYLENE•Polypropylene, compounding of modified technical PP blend. •Cellulose acetate , Polysulfones,…•Antistatic, masterbatches. •EVOH•Adhesives•PVC additives MBS, acrylics and processing aids) •Purging compounds (Dyna-purge ®)
ELASTOMERS•RUBBER Polychloroprene ,Ephichlorohydrin, Polyacrylic,Chlorinated Polyethylene,Fluoroelastomers,…
POLYURETHANES
& COATINGS
[email protected] www.cqmasso.com
POLYURETHANE•TDI Polyester and Polyether•MDI Polyester and Polyether•MOCA•ADDITIVES…COATINGS
• IRON OXIDES· RESINS (hydrocarbon, alkyl, polyurethanes, epoxy.)· INDUSTRIAL BIOCIDES· COAL TAR COMPOUNDS· FATTY ACIDS· ETHYL SILICATE· STABILIZERS·· TITANIUM OXIDE (Rutile)· ORGANIC PEROXIDES· Lactate Esters as solvents
• Raw materials and specialities for ceramicproducers AS:
•CLAYS "ball clays" type•CALCINED ALUMINAS •KAOLIN•CORONDUM• VANADIUM (PENTOXIDE , AMMONIUM METAVANDATE)•ZIRCONIM OXIDES•REFRACTORY PRODUCTS•CERAMIC ROLLERS •The manufacture of additives( deflocculants, fixative agents, glues )
•WAXES
CERAMICS
www.massoaditivos.comE_mail: [email protected]
•Coating kaolin's•Iron oxide•Talc for antipich, filler & Coating•Defoamers and Deaerators•Deinking products •Ceramic dewatering elements •Plastic dewatering elements •Pigments•Oil & Grease resistant • Fluorochemical• TiO2
TEXTILE
•Dyestuffs • Auxiliaries for all types of fibres
PAPER & TEXTILE
PAPER
ELECTRONICS & NDT &
PETROLEUM ADDITIVES
www.cqmasso.com
ELECTRONICS Base materials for manufacturing PCB’s FR4, FR2, CEM1 low Dk laminates.. Photploter film, Soldermask, microetches, solder and film strippers, HAL fluxes, etc…
NDT (Non Destructive Testing)X-Ray filmsRadiografic consumablesLead Intensifiing screensLiquid PenetrantsMagnetic Particles
PETROLEUM ADDITIVES
Canada
USA
Brazil
Australia
Japan
China
India
RUSIA
Kenia
ISRAEL
INTRODUCTIONINTRODUCTIONFirst of all I am going to do a little review of First of all I am going to do a little review of main actors within supply chain, before to main actors within supply chain, before to start talking about REACH implementation.start talking about REACH implementation.
After that ,I will focus my presentation on After that ,I will focus my presentation on How implements REACH for a new product / How implements REACH for a new product / substance manufactured or imported for first substance manufactured or imported for first time after 1st Dectime after 1st Dec´́08. (When first phase of 08. (When first phase of REACH Regulation finished)REACH Regulation finished)
DEFINING THE ROLE :DEFINING THE ROLE : MAIN ACTORSMAIN ACTORS
B=EU B=EU ManufacturerManufacturer
A=A=UserUser
& & importerimporter
& & exporterexporter
SB1SB1
SB2SB2
PC1PC1
P3P3
EUROPEAN UNIONEUROPEAN UNION
SC2SC2
C=NonC=Non--EUEUManufacturerManufacturer
DU=DU=DownDown
StreamStream
UserUser
SC1SC1
PC1PC1 SC2SC2
FIRST STEP :SUBSTANCE FIRST STEP :SUBSTANCE IDENTIFICATIONIDENTIFICATION
An important step at this moment is to do the inventory of all substances and preparations, specifying their composition, if they are imported AN important field that must be known for each substance are:
Chemical Name (IUPAC and others)CAS Number EINECS Number (European inventory of Existing chemical substances)
(Substances listed in EU inventory are known as PHASE-IN SUBSTANCES and can benefit from and extended deadline for registering, depending on the total quantity manufactured or imported per year)
SECOND STEP: SUBSTANCE SECOND STEP: SUBSTANCE EVALUATIONEVALUATION
Once we have all information Once we have all information about the substance , we are able about the substance , we are able to evaluate what we have to do to evaluate what we have to do with it.with it.Depending on these data we have Depending on these data we have 3 different options:3 different options:
SUBSTANCE STATUSSUBSTANCE STATUSEVALUATION OF SUBSTANCEEVALUATION OF SUBSTANCE
NON PHASE-IN SUBSTANCE
EXEMPTEDSUBSTANCE
REGISTRATION
PHASE-INSUBSTANCE
LATE PRE-REGISTRATION
EINECS AVAILABLE
NO EINECS
EXEMPTIONSEXEMPTIONSMedical products for human or Medical products for human or veterinary useveterinary useFood additives in foodstuffsFood additives in foodstuffsFlavouring in foodstuffsFlavouring in foodstuffsAdditives in feeding stuffsAdditives in feeding stuffsSubstances in plant protection and Substances in plant protection and biocidalbiocidal products.products.Polymers(*)Polymers(*)ANNEX IV & VANNEX IV & V
POLYMERSPOLYMERS
POLYMERS HAVE NO EINECS POLYMERS HAVE NO EINECS NUMBER ASSIGNED NUMBER ASSIGNED POLYMERS ARE EXEMPTED POLYMERS ARE EXEMPTED BUTBUT MONOMERS MUST BE PREMONOMERS MUST BE PRE-- REGISTERED/REGISTEREDREGISTERED/REGISTEREDWHAT HAPPEN WITH IMPORTED WHAT HAPPEN WITH IMPORTED POLYMERS?POLYMERS?
IMPORTED POLYMERSIMPORTED POLYMERSEUROPEAN EUROPEAN MANUFACTURERSMANUFACTURERSIF Polymerization IF Polymerization process is made process is made with monomers prewith monomers pre--registered or registered or registered by other registered by other European European companies,THENcompanies,THENPOLYMER POLYMER EXEMPTEDEXEMPTED
NONNON--EUROPEAN EUROPEAN MANUFACTURERSMANUFACTURERS
Have Monomers been Have Monomers been prepre--registered /registered registered /registered in EU by other previous in EU by other previous actors (manufacturer)?actors (manufacturer)?If YESIf YES
POLYMER EXEMPTEDPOLYMER EXEMPTEDIf NO If NO
MONOMERS (Bounded or MONOMERS (Bounded or not ) MUST be prenot ) MUST be pre--registered in EU when registered in EU when they are over 2%they are over 2%
ANNEX IV & VANNEX IV & VSome substances are EXEMPTED Of Some substances are EXEMPTED Of REACH REGISTRATION.REACH REGISTRATION.We can find them in ANNEX IV where We can find them in ANNEX IV where some CAS numbers are listed (Ex: some CAS numbers are listed (Ex: sodium sodium gluconategluconate , some fatty acids) , some fatty acids) and in ANNEX V where some criteria and in ANNEX V where some criteria have been established in order to allow have been established in order to allow some substances under some some substances under some conditions to be exempted conditions to be exempted (Ex. Natural products not dangerous (Ex. Natural products not dangerous and not chemically modify )and not chemically modify )
THRID STEP: QUANTITY THRID STEP: QUANTITY The quantity manufactured and / or imported to the EU is very important in order to decide if we are in time or not for submitting Late Pre-registration.If we manufacture and import the same substances we have to considerer the Total amount.If we manufacture for some different uses , we have to discount the amount of kilos for exempted applications.
LATE PRELATE PRE--REGISTRATIONREGISTRATIONArt.28 6) Potential
registrants
who
manufacture or
import
for
the
first
time a
phase-in substance
(>1 Tn/y ) or
use for
the
first
time a phase-in substance
in the
context
of
production
of
articles
or
import
for
the
first
time
an
article
containing
a phase-in substance
that
would
require
registration, after
1 December
2008, shall
be entitled
to
submit
pre-registration
within
six
months
of
first
manufacturing, importing
or
using
the
substance
and
no later
than
12 months
before
the
relevant
deadline
in Article
23.
31 Nov. 2009 31 MAY 2012 31 MAY 2017
≥1000 TNCMR cat.1 y 2
R50/53 ≥
100 TN
100-1000 TN 1-100 TN
SUMMARIZINGSUMMARIZING……..IDENTIFICATION
EINECS
DEAD LINE(IN TIME)
PRE-REGISTRATIONSUBMISSION
REGISTRATIONSUBMISSION
YES
NO
NO
YES
EXEMPTEDNO
EXEMPTED
NO
YES
NO
NO ACTIONS NEEDED
Registration process will be explained by
B&B at the end of this
conference.
AFTER PREAFTER PRE--REGISTRATIONREGISTRATIONOnce the pre-registration has been done (simple and free of cost), the company will be part of a SIEF (Substance Information Exchange Forum) , a database containing the names of the different manufacturers /importers of the same substance.We should identify the Leader , analyze the number of members , and check if our substance fulfill with the sameness of the substance (purity ,impurities…)However, it can be developed a preliminary assessment to see if other companies are interested in the same substance, how much of that substance they currently manufacture and commercialize and what data is currently available. Define the substances to be pre-registered and establish contacts with other companies to share data.AT THIS POINT IS TIME TO START REGISTRATION PROCESS!!
CURRENT SITUATIONCURRENT SITUATIONAt this moment , we are still working with all At this moment , we are still working with all products/substances manufactured and/or imported products/substances manufactured and/or imported before REACH entered into force (Dead lines 2013 & before REACH entered into force (Dead lines 2013 & 2018) 2018) In most cases our suppliers have implemented REACH In most cases our suppliers have implemented REACH themselves through :themselves through :
A consulting company as OR (Only Representative)A consulting company as OR (Only Representative)Their own offices in EU as ORTheir own offices in EU as OR
In other cases through a single DISTRIBUTOR as their In other cases through a single DISTRIBUTOR as their OR. (OR. (MassoMasso has developed this role for some Nonhas developed this role for some Non--EU EU manufactures)manufactures)
TO CONCLUDETO CONCLUDE……REACH IS A COMPLICATE REGULATION REACH IS A COMPLICATE REGULATION
....……BUT A LOT OF COMPANIES AS B&B, BUT A LOT OF COMPANIES AS B&B, MASSO AND MANY OTHER ARE MASSO AND MANY OTHER ARE WILLING TO HELP NONWILLING TO HELP NON-- EUROPEAN EUROPEAN MANUFACTURES.MANUFACTURES.
THANK THANK YOU!YOU!