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REACH implementation
On 1st June 2007,
REACH entered into force. Based on the Registration, Evaluation and Authorisation of Chemicals, REACH is a highly original new integrated system. It requires ‘downstream users’ such as the tyre and rubber industry to gather information on the properties of the substances that they use, to promote their safe management and to progressively substitute the most dangerous substances with safer alternatives.
From June to December 2008, there are only 6 months to comply with the requirements of the pre-registration phase. In the tyre and rubber sector, this will concern approximately 4000 raw materials of which 90% in the form of preparations.
REACH and the Tyre and Rubber Industry
The European Tyre and Rubber Manufacturers share the objectives of the Commission to improve the protection of human health and
the environment by gathering more information on the potential risks arising from the production or use of chemicals.
However, the final text issued in December 2006 delivered mixed results. This is because certain elements that could have considerably
increased the workability of REACH for the downstream users and SMEs have been watered down or not addressed at all by the Council and
Parliament. As far as the Registration phase is concerned, the duty to notify on an intention not to register a substance and the
proportional cost sharing remain examples of areas that do not facilitate the application of the requirements.
Regarding authorisation, the retained ‘hazard’ based approach in obliging the substitution of all substances of high concern independently
of the risks they could pose or not to human health and the environment, might lead to a very extensive and costly procedure or even to a
redevelopment of the product.
Therefore, the implementation phase of REACH will prove to be a major challenge for the industry and in particular for the smaller companies.
ETRMA’s objective is to find workable solutions and to ensure that the REACH Implementation Projects (RIPs), which are expected to issue
guidelines in June 2007, are properly developed and put in place by the authorities.
ETRMA is committed to playing an active role in helping the member companies successfully meet REACH challenges.
Update 28 May 2008
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