What the new EU REACH regulation means for your business

Abstract

The REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation entered into force throughout the European Union on 1 June 2007, with phased implementation from 2007 until 2018. This regulation is already having an effect on all chemicals, (including such diverse materials as alloys, paints and powders) used across the Aviation Industry in the EU, including those that are bought outside the EU throughout the global supply chain. The fi rst step of the regulation – pre-registration – has now closed, but some companies were unaware of their obligations, and now are fi nding themselves to be non-compliant with the law – and others are fi nding that their suppliers did not fulfi l their obligations, and have a risk of supply continuity. As a consequence of REACH, some essential chemicals may become restricted and even removed from the market. The fi rst of these are some phthalates that are in many plastics and adhesives, as well as chemicals of direct interest to the surface treatment industry such as sodium dichromate and cobalt dichloride, and a few fl ame retardants. Are you affected by the fi rst of these substances to be earmarked to be phased out? The implications of REACH for platers and coaters has been summarised recently by Oliver1. The regulation will also affect certain hazardous chemicals (including alloying constituents) within products. Customers and the EU REACH Agency will need to be informed of the presence of some substances within each product and spare part. This information will have to be supplied for products made outside the EU, and imported, as well as the products made within the EU. This requirement is already here. There are 15 substances which may be in electrical equipment, non metallic parts or in surface coatings that you may have in your products and that you may be required to declare to customers. You need to know if these chemicals are in your products. The Midlands Aerospace Alliance together with major aerospace product manufacturers recognises the impact that this regulation will have on all companies, both large and small and held a workshop on the 3rd March 2009 to help companies to work through the legislation. Speakers included representatives from Airbus, Goodrich, GE, Lockheed, Meggitt and Rolls-Royce and represented the shared knowledge of these organisations.