REACH GETTING READY FOR JUNE 2018 MANCHESTER • 22 MAY 2017 Mervyn Chung-Fat, Marketing Director EMEA
WHAT IS REACH? REACH is the European Regulation for: Registration, Evaluation, Authorisation and Restriction of Chemicals • For the Protection of Human Health and the Environment • Adopted by all 31 countries within the European Economic Area (EEA) • Register all substances by the volume used • Evaluate the risk for health and the environment by numerous lab tests depending on the volume and exposure of humans to the substance • Authorize use of dangerous chemical under specific conditions to keep safe those that will be exposed
CHANGING THE WHOLE CHEMISTRY INDUSTRY
WHAT HAS TO BE REGISTERED? ®
MATERIAL X SUBSTANCE A
SUBSTANCE B
SUBSTANCE C
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VOLUME + USES
TOXICITY TESTING ANNEX VII – 10t
ANNEX VIII – 10-100t
Cost: 75k euro ~175K • Time: ~?months
Cost: 225k euro ~475K • Time: ~?months
USE SCENARIOS Scenario E – Handling and dilution of metalworking fluid concentrates
Add concentrate to water
Sample solution Test concentration
Equipment cleaning and maintenance
Disposal of waste and used containers
Material Storage
YOU ARE RESPONSIBLE TO INFORM YOUR SUPPLIERS IF YOU USE DIFFERENTLY THAN SPECIFIED
RISK OF NON-COMPLIANCE (IN EEA) Non-compliant products cannot be sold after May 31, 2018.
PRODUCTION STOPPAGE
Use of non-compliant products can lead to closure of establishment
FINES
Fine for non-compliance vary by country; going up to 55M€ in Belgium and unlimited in the UK
Source: http://ec.europa.eu/environment/chemicals/reach/pdf/report_reach_penalties.pdf
CRIMINAL CHARGES
Companies can face criminal charges. Prison sanctions from 6 months to 5 years
HOUGHTON REACH SITUATION TODAY Assessment with Available Raw Material Information 7%
5% 11%
Finished Products
Based on 2016 Volume
REACH Compliant
28%
Expected Compliance Register/Reformulate
49%
Under Review Stopping
HOW ARE WE COMMUNICATING WITH CUSTOMERS?
TAKE AWAY
• Many raw materials are disappearing because of REACH • Cost of registration significantly increasing as we approach 2018 • More pre-registered materials are expected to disappear • Review all your chemicals availability for the future • Houghton is on plan to be REACH ready. Are you?
BE READY HOUGHTON!
Thank you. Any questions?