The Implications of REACH for the Plastics Industry

Sarah PlantIndustrial Issues Executive

About the BPF…

• the leading trade association of the UK Plastics Industry

• encompasses over 600 companies from the plastics industry supply chain, including polymer producers, suppliers and processors in addition to additive and machinery suppliers and manufacturers.

• authoritative, well-respected and objective source of unique information, views and commentary whose name has, as a consequence, become synonymous with plastics in the UK.

Aims of REACH

• improve the protection of human health and the environment while maintaining the competitiveness and enhancing the innovative capability of the EU chemicals industry.

• Responsibility for chemical safety passed to industry

Implications of REACH

• Obligations vary in the supply chain

• Manufacturers / Importers will have the most to do

• Downstream users required to ensure their interests will be covered

Implications of REACH for the Plastics Industry

• Complex series of supply chain structures

• Complex Communication Networks

• Rationalisation of Substances

• Fear of end-user ‘blacklists’

• Planning for compliance needs to begin now – pre-registration from 1st July 08

Identifying role within REACH - Definitions

Manufacturer: Any natural or legal person established within the EU who manufactures a substance within the EU

Importer: Any natural or legal person established within the EU who is responsible for import

Distributor: Any natural or legal person established within the EU, who only stores a substance for supply to another actor in the supply chain

Downstream User: Any natural or legal person established within the EU, who uses a substance, either on its own or in a preparation , in the course of his industrial or professional activities.

Issues within the supply chain

• The issues to be addressed may be different depending upon your position within the supply chainManufacturers (including additives

suppliers)ImportersDistributorsDownstream Users (processors /

formulators / article manufacturers)Recyclers

Issues affecting Manufacturers

• Pre-Registration1st June 2008 – 1st December 2008

• Data Evaluation• Data Sharing: SIEF’s

• Development of Exposure Scenarios:Communication through the supply chain

• Registration:Compilation of CSA/CSR

• Risk Assessment:Agree Risk Management Measures with DU’sCommunicate down the supply chain through MSDS

Issues affecting Importers

Article 6 (3):Any importer of a polymer shall submit a registration to

the Agency for the monomer substance(s) or any other substance(s), that have not been registered by an actor up the supply chain, if both of the following

conditions are met: a) the polymer consists of 2% weight by weight (w/w) or

more of such monomer substance(s) or other substance(s) in the form of monomeric units and chemically bound substance(s);

b) the total quantity of such monomer substance(s) or other substance(s) makes up one tonne or more per year.

Issues affecting Importers (2)

• Nominate ‘only representative’ within the EU

• Pre-register all substances

• Register with SIEF’s

• Communicate with downstream users

Issues for Distributors

• No need to register (unless importing from outside EU)

• Communicate up and down the supply chain:

- information on intended use for exposure scenarios- flow of information on hazards and safe use

• Timeframe dictated by supplier• DU’s must agree on suppliers risk

management measures

Issues for Downstream Users

• No accountability for registration (unless importing from outside EU)

• Possibility of cost increases

• Possible loss from market of low volume but critical in use additives

• Substitution leading to loss of function

Issues affecting Recyclers

• Waste is not a substance, a preparation or an article within the meaning of REACH.

• Once waste is recovered and in this recovery process another substance, preparation or article is produced, comes back into REACH

• Basic polymer / additives • Legacy additives

Summary of Potential Issues

• Complex Communications Network• Changes within current markets

- Loss of supplier- Loss of raw material- Loss of function- Loss of product

• Loss of Customer• Fear of end user blacklists• RIP’s still incomplete• UK enforcement regime and required legislation will

not be finalised until 2008.

Conclusions

• Plan as early as possible for tight timescales, resources and budgets

• Awareness of your position in the chain and subsequent role under REACH (manufacturer / importer / DU) for each substance

• Work to support customers and identify uses• Develop good communication networks

throughout the supply chain

BPF Guidance

• REACH Toolbox• Successful Series of Seminars:

29th November – PERA, Melton Mowbray • Membership of EuPC:

– access to the EuPC Help Desk– EuPC Inventory Tool & Manual

• Interventions with UK National Authorities:

DEFRA, DTI, HSE

The End…

Any Questions?

Sarah Plant

Industrial Issues Executive

Tel: 0207 457 5015

Email: splant@bpf.co.uk