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REACH at LANXESS. LANXESS Procurement North America Thomas J. O'Neill CPO. Agenda. 1. LANXESS at a glance. 2. REACH at a glance. 3. REACH at LANXESS Procurement. Agenda. 1. LANXESS at a glance. 2. REACH at a glance. 3. REACH at LANXESS Procurement. Sales in the year 2007.

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Reach at lanxess


LANXESS Procurement North AmericaThomas J. O'Neill CPO



LANXESS at a glance


REACH at a glance


REACH at LANXESS Procurement



LANXESS at a glance


REACH at a glance


REACH at LANXESS Procurement

Reach at lanxess

Sales in the year 2007

EUR 6,608 bn

Sales thru 3rdQ/2008

EUR 5,114 bn

Employees worldwide (as of: 2008-09-30)



Performance Polymers

Advanced IntermediatesPerformance Chemicals

Global orientation

Around 44 sites

21 countries

LANXESS is one of Germany’s most important providers of polymers and chemicals

Reach at lanxess









Burgettstown, PA















de Mar




Bushy Park/SC



Cabo de Santo Agostinho










Duque de Caxias


Lanxess Production Sites

Lanxess has built a strong portfolio with leadership businesses
LANXESS has built a strong portfolio with leadership businesses

LANXESS Portfolio 2008

  • 13 Business Units substantially restructured and repositioned

  • All BUs now occupy leadership positions in their markets

  • Strategic divestments of four Business Units:

    • Fibers

    • Paper Chemicals

    • Textile Processing Chemicals

    • Lustran Polymers

  • Strategic Acquisitions

    • Petroflex

    • Chrome International South Africa



Profitability and stability expectation

LANXESS Business Units


Agenda businesses


LANXESS at a glance


REACH at a glance


REACH at LANXESS Procurement

R egistration e valuation and a uthorization of ch emicals reach

Created a single European Union regulatory scheme for all chemical substances.

Entered into force on June 1, 2007 with 11 year phase-in period.

European companies and non-European companies that ship chemical products into Europe, have customers that ship products into Europe, and/or purchase products from Europe are impacted.

Industry is given more responsibility. The government no longer must scientifically prove that the use of a substance is dangerous.

The chemical industry must demonstrate (in conjunction with the user) that the use of a certain substance under normal circumstances is safe.

Registration, Evaluation, and Authorization of Chemicals (REACH)

Key reach requirements

Pre-registration chemical substances. : Companies pre-register at no cost on-line providing basic information on substance identity and company. Allows phased-in registration and identifies companies that produce the same chemical to share information and develop joint registration packages.

Registration: Requires submittal of a technical dossier with extensive data on the toxic characteristics of the substance, which will entail substantial testing and data gathering. Will be substance specific and chemical manufacturer or importer specific.

Key REACH Requirements

Reach registration deadlines
REACH - Registration Deadlines chemical substances.

REACH provides an extended time period for registration only for companies which have pre-registered their substances


≥ 1,000 tons per year

Carcinogenic, Mutagenic or toxic for Reproduction ≥ 1 ton per year

Very toxic to aquatic organism ≥ 100 tons per year

REACH entered into force

100-1,000 tons per year

100-1,000 metric tons per year

1-100 tons per year

June 1,

Nov. 30,

May 31,

May 31,





Dec. 1,

June, 1



Reach strategies for non eu companies exporting to the eu

Supplier Registration chemical substances. Register via an EU-based ‘Only Representative’


Depend on EU based customers to register as an importer

Customer RegistrationCustomer registers as importer and has responsibility for REACH requirements

REACH Strategies for Non-EU Companies exporting to the EU

Cost of registration depends on quantities properties and uses of the chemicals

Quantities manufactured or imported chemical substances.

10 - 100 mt/y


> 1000 mt/y

1 - 10 mt/y

Required tests according to:


Annex VII-IX

Annex VII-X

Annex VII


Registration documents

Technical Dossier

Chemical Safety Report (CSR)

Exposure evaluation and risk assessment*

Increasing Costs

Cost of registration depends on quantities, properties and uses of the chemicals

*if sustances are classified as „dangerous“

Registration as intermediate article 18 certificates
Registration as Intermediate chemical substances. (Article 18-Certificates)

  • Substances declared as intermediates and handled under strictly controlled conditions result in reduced administrative costs.

  • Registration as intermediate can save up to 80 T€ per substance only in administration cost.

  • Additional costs for required tests can be estimated after gap analysis.

Diff. = 80 T€

Agenda chemical substances.


LANXESS at a glance


REACH at a glance


REACH at LANXESS Procurement

Reach strategy at lanxess
REACH Strategy at LANXESS chemical substances.

  • Complete Pre-Registration of the current LANXESS portfolio.

  • Pre-Registration of substances with possible future relevance.

  • Pre-Registration of all Raw Materials independent of supplier's intention to register.

  • Pre-Registration of strategic substances for all LANXESS Legal Entities within the EU independent of our current production sites.

  • For LANXESS Legal Entitiesoutside of the EU, LANXESS GmbH acts as ‘Only Representative’ so that they can export into the EU.

“Keep every option open”

Lanxess procurement reach implementation
LANXESS Procurement REACH Implementation chemical substances.

Ensure future delivery of raw materials and maintain flexibility in sourcing

  • Ensure further delivery of raw materials and maintain flexibility in sourcing

  • Request our vendor’s intention to pre-register / register via a standardized questionnaire

    • We expect complete pre-registration and registration of all substances supplied by our vendors.

  • Own Pre-Registration of all raw materials (current and future portfolio) independent of vendor’s intention to register

    • Enables LANXESS to act as an importer with extended registration periods.

Supplier survey 2008
Supplier Survey 2008 chemical substances.

An eQuestionnaire-Tool was implemented to ensure automation of requests and efficient documentation of supplier replies

How we minimized open requests:

  • Vendors who didn’t reply sufficiently were reminded by an automated procedure.

  • Any Open Vendor/Material combinations were followed up directly by the responsible Purchasers (Business Contacts).

Reach supplier survey 1860 substances
REACH Supplier Survey (1860 Substances) chemical substances.

REACH compliant substances


No interruption in future supply is expected

What do we expect from a non eu based supplier and his only representative
What do we expect from a non-EU based Supplier and his ‘Only Representative’?

  • Complete pre-registration and registration of all REACH relevant substances delivered to LANXESS

  • Written statement that he has appointed an “Only Representative”

  • Pro-active information about status and progress

  • Cost Transparency in terms of REACH

  • All LANXESS applications are to be covered by registration

Reach at lanxess procurement next steps
REACH at LANXESS Procurement: Next Steps ‘Only Representative’?

  • Estimate cost and evaluate impact on supply portfolio

  • Prepare own exposure scenarios and risk assessments to protect Intellectual Property in terms of sensitive end-uses

  • Consider option to register on our own

Reach at lanxess

Thank you very much for ‘Only Representative’?

your kind attention.

Backup questions and answers
Backup: Questions and Answers ‘Only Representative’?

What does LANXESS expect from a supplier's "OR"?

Competent preregistration and registration of the substances to be delivered. The LANXESS uses should be covered in the Exposure Scenario annex to the Safety Data Sheet.

Will LANXESS show preference to suppliers that allow you to act as OR. Have you aggressively marketed your OR activities and if so - do you have many companies that have signed on?

LANXESS will only act as OR for own subsidiaries outside the European Community

Backup questions and answers1
Backup: Questions and Answers ‘Only Representative’?

Intermediates - are you planning capital improvements to your facilities so that intermediates can be rigorously contained?

There should be no need as intermediates are already handled under safe conditions at LANXESS. In any case, all intermediates are being reviewed for REACH compliance.

Did LANXESS pre-register products you purchase? If so, in instances where several suppliers also pre-register, do you intend to register? How will LANXESS handle the next stages

LANXESS preregistered all needed substances as a precaution. Registration will be done in single cases only,

e. g. for possible imports after cost-benefit analysis.

Backup questions and answers2
Backup: Questions and Answers ‘Only Representative’?

What is LANXESS doing about products you buy that were not pre-registered by any suppliers - if any?

LANXESS pre-registered all substances needed and would be able to act as importer/ manufacturer.

How will LANXESS handle SIEF participation for products pre-registered that are not produced by LANXESS (this assumes you have some!)?

LANXESS may not be able to provide information or data from previous studies but we may have to participate in the costs of future studies required to register under REACH.

Backup questions and answers3
Backup: Questions and Answers ‘Only Representative’?

Is LANXESS doing anything special to protect your IP - especially in regards to "sensitive" end uses for purchased products?

Yes, of course, LANXESS may prepare own exposure scenarios and risk assessments to protect Intellectual Property in terms of sensitive end-uses

Will REACH have an impact on where LANXESS sources toll production?

Maybe – any incremental costs for registration for toll produced products will have to be considered.

Backup questions and answers4
Backup: Questions and Answers ‘Only Representative’?

Will LANXESS preferentially purchase products from companies that are pro-active about REACH?

We expect REACH compliance from all of our suppliers: No REACH compliance means no business.

Will you help suppliers comply with registration by offering to offset the costs?

LANXESS expects competitive raw material costs, even under the conditions of the REACH regulation

Backup questions and answers5
Backup: Questions and Answers ‘Only Representative’?

Supplier survey - were there consequences for no response? Did you succeed in getting responses from enough of your suppliers to convince you that acquiring raw materials will not be a problem?

Based on the results of our survey we do not expect any future interruptions in supply due to REACH.

How do you intend to handle SIEF participation - with internal resources or external resources?

Regarding our purchased raw materials, we are not an owner of data. Therefore our SIEF activity will be limited. There should be no need for LANXESS to employ external resources.

Backup questions and answers6
Backup: Questions and Answers ‘Only Representative’?

Does LANXESS have the ability to perform necessary registration testing in house. If not, how will you go about outsourcing this activity?

LANXESS has arranged contracts with external service providers to perform any testing required for registration under REACH.