REACH regulation

In December 2006, the EU Council of Ministers in the EU Parliament endorsed the REACH regulation. This regulation has been in force since 01 June 2007. Up until 31 May 2008, the previous regulations of the Chemicals Act applied. The new regulation fundamentally changes the responsibilities in assessing the risk of substances. Beforehand, these have mainly been assessed by the authorities. Since the introduction of REACH, the manufacturer and/or importer plays a considerably, more prominent role in the assessment of risk. The classification into "old substances" and "new substances" has been consigned to history and both are now equally assessed . Each substance must be registered with the EU Chemicals Agency (ECHA), according to its applications.
On 01 June 2008 began the six-month pre-registration phase, in order to use the transitional period for the final registration of so called "phase-in substances" (old substances under "EINECS"). The manufacturers of our products are generally trying to pre-register all substances. This pre-registration is not application-specific. Only for the final registration due by 2010 (2013 or 2018, according to the respective annual production volume) information on application, exposure and risks in down-stream uses of substances must also be reported.

As soon as the specific implementation conditions of REACH are known, we will, therefore, contact our customers to ask them for necessary information to allow us or our manufacturers to register the substances for customer-specific applications. In order to avoid repetition of requests for information, we plan to wait for the harmonized VCI or CEFIC questionnaire before making contact with you regarding your applications of the substances. This, however requires, among other things, the final provisions of "RIP 3.2" ("REACH Implementation Project, Guidance Documents for Industry, - preparing the Chemical Safety Report [CSR]"), planned to be published soon. We shall then approach our customers, in line with the participating associations (CEFIC and VCI) and our manufacturers.

On top of our obligation to implement and comply with the principles of the Responsible Care programme, we regard ourselves as a responsible distributor and we shall continue our close involvement with REACH today and in the future, in order to support the most important objectives for

• improving protection of human health and the environment
• improving the chemical industry's competitiveness within the EU