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.
LANXESS Procurement North AmericaThomas J. O'Neill CPO
EUR 6,608 bn
Sales thru 3rdQ/2008
EUR 5,114 bn
Employees worldwide (as of: 2008-09-30)
Advanced IntermediatesPerformance Chemicals
Around 44 sites
LANXESS is one of Germany’s most important providers of polymers and chemicals
Cabo de Santo Agostinho
Duque de Caxias
Lanxess Production Sites
LANXESS Portfolio 2008
Profitability and stability expectation
LANXESS Business Units
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)
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 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
Depend on EU based customers to register as an importer
Customer RegistrationCustomer registers as importer and has responsibility for REACH requirementsREACH Strategies for Non-EU Companies exporting to the EU
10 - 100 mt/y
> 1000 mt/y
1 - 10 mt/y
Required tests according to:
Chemical Safety Report (CSR)
Exposure evaluation and risk assessment*
Increasing CostsCost of registration depends on quantities, properties and uses of the chemicals
*if sustances are classified as „dangerous“
Diff. = 80 T€
“Keep every option open”
Ensure future delivery of raw materials and maintain flexibility in sourcing
An eQuestionnaire-Tool was implemented to ensure automation of requests and efficient documentation of supplier replies
How we minimized open requests:
REACH compliant substances
No interruption in future supply is expected
your kind attention.
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
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.
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.
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.
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
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.
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.