REACH – its implications for platers and coaters

Abstract

The REACH (Registration, Evaluation and Authorisation and Restriction of Chemicals) Regulations have been enshrined in European Law since 1st June 2007. These require that virtually all substances (other than naturally occurring materials) that are imported or manufactured in the European Union by any legal entity, in quantities of 1 tonne or more, will have to be registered with the European Chemical Agency, ECHA, in Helsinki. To legally trade any substances in quantities greater than 1 tonne, pre-registration must be carried out by November 30th 2008. Failure to do so means NO DATA – NO MARKET. Pre-registration is free of charge and is fairly simple. Details that must be submitted includename, address and telephone number of manufacturer or importer, Reach Contact, substances to be registered and quantities to be used. It has been estimated that some 30,000 substances will need to be registered, and in the United Kingdom alone, about 250,000 companies will need to carry out registrations. Pre-registration gives organisations a period of grace before registration has to be completed. Registration, which will be expensive and complicated, will be phased in, and in order to furnish the European Chemical Agency with the information they need to grant a registration, companies can form a SIEF (Substance Information Exchange Forum) to minimise animal testing, environmental exposure monitoring etc. Nevertheless, registration could cost many thousands of euros depending on the complexity of the work to be carried out, to produce a satisfactory dossier. Registration for substances produced or imported in quantities greater than 1000 tonnes, or substances of very high concern (see tabulated list) needs to be done by July 2010; if quantities are greater than 100 tonnes, the date is July 2013; and if only 1 to 100 tonnes are involved the Agency must have all the information by July 2018. Metal finishers and surface coaters are catagorised as ‘‘downstream users’’ under REACH, so will not have to register substances themselves. They will, however, need to ensure that suppliers of all materials they use (including hydraulic oil in fork lift trucks and lubricants for conveyor bearings) have pre-registered materials to allow their businesses to continue. The traditional ‘‘supply houses’’ are well informed about what they need to do, but small engineering suppliers are not all up to date with the regulation and may need advice. Substances of Very High Concern are unlikely to be allowed to be used, and with a non-refundable fee of 30,000 euros even to apply for registration, realistically they will probably be phased out. Use will only be allowed if there are strong socioeconomic arguments or if an alternative material is not available. The Substance of Very High Concern list (see Table) will not be very long, it is estimated that it will eventually contain about 100 materials. Of far greater significance to industry as a whole, is that it is thought that between 10–40% of substances that need to be registered will not be included because the costs will be too great for registration to be viable. During registration, downstream users will need to ensure that the way that they employ a particular substance is included in that registration, but this may not be too onerous, for categories of use are fairly wide; for example, laboratory chemicals or water treatment. It is certain that the regulation will have a significant impact on the surface plating and coating business, but how great this will be remains to be seen.