On 1 June 2007, the Reach regulation 1907/2006 (Registration, Evaluation, Authorization and Restriction of Chemicals) came into effect. Reach requires every marketable substance to be registered with the new European Chemicals Agency (ECHA). The implementation of Reach will have significant impacts on all players involved in the supply and use chain for chemical products in the European Union.
Casco Adhesives and REACH
Casco Adhesives is mainly a downstream user of chemical substances and preparations (in a few cases also a manufacturer or importer), that manufactures adhesive systems. These products are defined as “Preparations” and as such they are exempted from registration under REACH. REACH applies only to the substances that are used for the manufacture of the preparations. The pre-registration period ended on 1 December 2008 and Casco Adhesives has made sure that all substances subject to REACH in our products have been pre-registered, either by us or by our suppliers. The registration of substances has to be completed by 1 December 2010 for high volume (>1000 t/a) and high concern products, 1 June 2013 for medium volume (100-1000 t/a) products and 1 June 2018 for low volume (1-100 t/a) products.
The process of gathering and following up on detailed REACH compliance information from our suppliers has been ongoing since 2007 and will continue throughout the registration period. We are committed to fulfilling all of our obligations in order to support the products we supply to our customers. As a company, our efforts are in agreement with the European Adhesives and Sealants Manufacturing Association (FEICA) and the European Chemical Industry Council (CE FIC).
Information in the supply
Communication along the supply chain is key to efficient implementation. The application and use of each substance have to be identified from the raw material supplier down to the end user (industrial and professional use), in order to evaluate the risk to humans and the environment. Manufacturers and importers must provide their downstream users with the risk information they need to use the substance safely. The downstream user on the other hand must provide the suppliers with information regarding intended application and use.
Substances of Very High Concern (SVHC)
REACH foresees an authorization system aiming to ensure that substances of very high concern are adequately controlled, and progressively substituted by safer substances or technologies, or only used where there is an overall benefit to society in using the substance. These substances will be prioritized and over time included in Annex XIV of the legislation. Once they are included, industry will have to submit applications to the Agency for authorization to continue using these substances. None of the substances in the raw materials that Casco Adhesives use in Europe are included in the first Candidate List of SVHC for inclusion in Annex XIV, and thus none are currently subject to possible Authorization and/or Restriction of Use.
Articles glued with bonding systems supplied by Casco Adhesives
A glued Article will only be subject to registration obligations under REACH if:
• The substances contained are intended to be released from the produced or imported article(s) during normal and reasonable foreseeable conditions of use OR
• After 1 June 2011, glued Articles produced in or imported into the EU contain any substance identified in Annex XIV (substances subject to Authorization) or the substance is included in the Candidate List for Authorization (Article 59(1)) and if the following are both true:
– The substance is present in those Articles above a concentration of 0.1% weight by weight,
– The substance is present in those Articles in total (annual) quantities exceeding one tonne per year.
None of the European products supplied by Casco Adhesives contain any substances that are intended to be released. None of the European products supplied by Casco Adhesives contain any of the substances in the first Candidate List for inclusion in Annex XIV, and therefore none will have any implications for REACH registration of Articles. For Casco Adhesives products outside of the European Union, please contact our local Casco Adhesives representative for further information.
Casco Adhesives views REACH not as a threat but as a business opportunity. We are committed to ensuring that Casco Adhesives implements REACH in the most successful manner possible, to the long-term benefit of our company, our customers and our suppliers.
For more information and guidance visit the
European Chemicals Agency; www.echa.eu. ■