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REACH information for our customers

In connection with REACH we receive lots of inquiries from our customers. We would therefore like to inform you about REACH and the stage reached in our work.

REACH is the EU legislation on chemicals and applies to all of us. 

As it is usual in business transactions, you can assume that your partner observes the law. 

Our suppliers have preregistered all of the substances contained in our products. This also applies to substances which we do not produce ourselves, including monomers of polymers. We therefore assume that within the scope of the supply chain relevant to you every substance has been pre-registered several times. 

The registration numbers of many substances have already been transferred to the material safety data sheets. 

For many of our raw materials, however, a later date applies, since these are specialities which are not produced in such large tonnages. For this reason, we can at the present time only say that the last registration numbers will be available by 2018. In any case you will receive a new material safety data sheet (MSDS) immediately after receipt of the registration numbers.

There is apparently a great deal of confusion regarding the obligation to provide information under Point 3 of MSDS. Art. 3.1 of Appendix II of the REACH Ordinance states that it is not necessary to state the complete composition of a product. According to Articles 3.2 and 3.3, only dangerous substances need to be stated. Art. 3.5 prescribes what is to be stated, namely the designation and the registration number assigned as well as, if provided, the EINECS or the ELINCS number. There is no obligation to provide the CAS numbers or the IUPAC designation. 

The most important means of information in the supply chain is the MSDS. From the MSDS you also obtain information on registration numbers and changes in the classification. REACH only demands that customers, which have purchased a product during the past 12 months should be informed. It goes without saying that you will receive an MSDS for all of the products purchased from us and not only for those for which the REACH Regulation prescribes it. 

As regards the use (Title V of the REACH Regulation), we will approach you in due course. In order to avoid unnecessary work we would like to ask you to not yet inform us of your use. At association level (inter alia Central Association of Surface Technology (ZVO)) there are projects in progress on exposure scenarios in order to cover all of the uses typical of our sector of industry.

REACH (and GHS) require a great amount of effort from all chemical companies. We comply with REACH. But REACH is not the purpose of our company. That consists now as ever in supplying you with qualitatively high-grade specialities and helping you with solutions for new technical challenges.