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Session 2: View by the industry. REACH Consequences for the Downstream industry - a Danish perspective Helle Simon Elbro DK-REACH project group/ hse consult. Manufacturer. DU Company. DU Company. DU Company. DU Company. DU Company. DU Company. External complexity. 30,000 substances.

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REACH Consequences for the Downstream industry - a Danish perspective Helle Simon Elbro

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Reach consequences for the downstream industry a danish perspective helle simon elbro

Session 2: View by the industry

REACH Consequences for the Downstream industry- a Danish perspective

Helle Simon Elbro

DK-REACH project group/hse consult


External complexity

Manufacturer

DU Company

DU Company

DU Company

DU Company

DU Company

DU Company

External complexity

30,000 substances

Nail

Varnish

remover

Acetone

Distributor

Soap &

Detergents

Professional

Application of

paint

Distributor


Internal complexity

Purchase of raw materials (x100)

BUT

Regulation is

on chemical

Substance level

(x100)

Sale of

Products

(x100)

Internal complexity

PRODUCT


Amount of high volume substances for a typical du company

Amount of High Volume substancesFor a typical DU-Company

Substances

Approx. 40%

High volume substances

Approx. 70% of raw

materials contains min. one high volume substance

Raw material

100% of products

contain min. one high

volume substance

Products


Amount of low volume substances for a typical du company

Amount of Low Volume substancesFor a typical DU-Company

Substances

Approx. 10%

Low volume substances

Approx. 20% of raw

materials contains min.

one low volume substance

Raw material

Products

Approx. 80% of products

contains min. one

low volume substance


Reach consequences

REACH Consequences

  • Extensive documentation work

  • Substances “disappear”

    →Reformulation of raw materials/products

  • Limited reaction time

  • Other issues

1. Importer role

2. DU role


Documentation acting as importer

Manufacturer

Substance

Raw material

Product

SDS

SDS

SDS

DU Company

Supplier

Registration

Authorisation

EU

EU Agency

Documentation acting as Importer

Customer


Documentation in du role 300 raw materials

2009

40

Collection of

own and

customer use

2012

Product

> 35

2017

SDS

SDS

DU company

Supplier

350

300

(75)

(150)

220 (40)

2009

2012

65 (35)

2017

Documentation in DU role300 raw materials

Communication

of identified use

Raw material

Customer

Check own and

customer use

with exposure

scenario


Documentation in du role 350 products

Product

SDS

SDS

DU company

Supplier

350

300

(75)

(150)

350 (150)

Combination of exposure

Scenarios from several

raw materials

270 (60)

Documentation in DU-role350 products

Raw material

Customer

2009

2012

2017


Reach consequences1

REACH Consequences

  • Extensive documentation work

  • Substances “disappear”

    →Reformulation of raw materials/products

  • Limited reaction time

  • Other issues


Substances disappear

Substances “disappear”

EU Commission:

1-2%

CEFIC

20-40%

(1-100 tonnage)

Commercial

reasons

Health & Environment

reasons

Mainly the

“speciality chemicals

(20/80 rule)


Products contain many substances

Problematic

Classified

Defined

Unknown

Products contain many substances

*) Defined substances either have a CAS-no or are classified


Options if substances disappear

Options if substances disappear

  • Dialogue with supplier

  • Establish more documentation

    • Together with supplier

    • Alone or in a consortia

  • Re-formulation of raw material>> Validation of product

  • Re-formulation of product

Increasing resource

and time requirements


Substances may disappear

Problematic

Defined

Unknown

Consider our options

Substances may disappear

- when prices are increasing

Classified


Substances may disappear1

Problematic

Defined

Different use

Unknown

Consider our options

Substances may disappear

- when not registered - or not for our use

No

registration

Classified


Substances may disappear2

Problematic

Defined

Different use

Unknown

Consider our options

Substances may disappear

- when not applied for authorisation or not for our use

Not applied

for authorisation

Classified


Substances may disappear when classified stronger

Problematic

Defined

Unknown

Consider our options

Substances may disappear- when classified stronger

Classified


Worst case is re formulation

“Worst case” is re-formulation!

  • Price increase of raw material

  • Substance in raw material is not registered – or not for our use

  • Substance in raw material does not get authorisation - or not for our use

  • New and stronger classification for one of the substances in a raw material

    And we don’t know how many and when substances/raw materials may disappear.


Reach consequences2

REACH Consequences

  • Extensive documentation work

  • Substances “disappear”

    →Reformulation of raw materials/products

  • Limited reaction time

  • Other issues


Limited reaction time repetitive work lack of control

Collection of own and

customer use

Communication

on identified use

SDS

SDS

DU Company

Supplier

350

300

(70)

(150)

2009

2012

2017

Limited reaction time Repetitive work – lack of control

Raw material

Product

Customer


Limited reaction time communication in supply chain can be complex

NEW INFORMATION

1st extended SDS

(Intended use)

Pre(Registration)

Limited reaction time Communication in Supply chain can be complex

GOODS

Decision on

Registration

Manufacturer

Supplier

Supplier

Distributor

DU Company


Limited reaction time if complicated re formulation is needed

Time

Years

Validation at (industrial) customer

Approval at Authorities

External documentation

Field evaluation

Lab-testing

Few days

Limited reaction time if complicated re-formulation is needed

New additive in functional product

(wood-stain)

Change of solvent based on

Certificate of Analysis


Reach consequences3

REACH Consequences

  • Extensive documentation work

  • Substances “disappear”

    →Reformulation of raw materials/products

  • Limited reaction time

  • Other issues


Other issues

Other issues

  • Loss of competitiveness.

    • Example: Import of ready-made articles from outside EU

  • Loss of innovation.

    • Example: No exemption for R&D on new uses in preparations (unlike PPORD on new substances)

  • Loss of confidentiality.

    • Example: Registration number on SDS


Reach consequences4

REACH Consequences

  • Extensive documentation work

  • Substances “disappear”

    →Reformulation of raw materials/products

  • Limited reaction time

  • Other issues


The end

THE END


Substances disappear1

  • Raw materials

  • To be reformulated

  • Or disappear

Substances “disappear”

 Products to be reformulated


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