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The Implications of REACH for the Plastics Industry

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Title: The Implications of REACH for the Plastics Industry


1
The Implications of REACH for the Plastics
Industry
Sarah Plant Industrial Issues Executive
2
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.

3
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

4
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

5
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

6
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.

7
Issues within the supply chain
  • The issues to be addressed may be different
    depending upon your position within the supply
    chain
  • Manufacturers (including additives suppliers)
  • Importers
  • Distributors
  • Downstream Users (processors / formulators /
    article manufacturers)
  • Recyclers

8
Issues affecting Manufacturers
  • Pre-Registration
  • 1st June 2008 1st December 2008
  • Data Evaluation
  • Data Sharing SIEFs
  • Development of Exposure Scenarios
  • Communication through the supply chain
  • Registration
  • Compilation of CSA/CSR
  • Risk Assessment
  • Agree Risk Management Measures with DUs
  • Communicate down the supply chain through MSDS

9
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
  • 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)
  • the total quantity of such monomer substance(s)
    or other substance(s) makes up one tonne or more
    per year.

10
Issues affecting Importers (2)
  • Nominate only representative within the EU
  • Pre-register all substances
  • Register with SIEFs
  • Communicate with downstream users

11
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
  • DUs must agree on suppliers risk management
    measures

12
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

13
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

14
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
  • RIPs still incomplete
  • UK enforcement regime and required legislation
    will not be finalised until 2008.

15
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

16
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

17
The End
  • Any Questions?
  • Sarah Plant
  • Industrial Issues Executive
  • Tel 0207 457 5015
  • Email splant_at_bpf.co.uk
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