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Regulatory Information

Other European Regulations

REACH

REACH is a European Union regulation and it stands for “Registration, Evaluation, and Authorisation of Chemicals which is administered by the European Chemicals Agency (ECHA). The purpose of REACH is to ensure that the effects of chemicals on human health and the environment are known before they are introduced into commerce. REACH affects the entire supply chain where it passes through the EU, including non-EU companies that export chemicals, chemical mixtures (called “preparations”), and some articles when exported to EU-based customers.

Registration Exemption for Articles

As defined by REACH, an article is “an object which, during production, is given a special shape, surface, or design which determines its function to a greater degree than its chemical composition.” Substances in articles need only be registered if they are exported to an EU member state and are present in quantities equal to or greater than one (1) metric ton per year and, the substance(s) therein are intended to be released under normal or reasonably foreseeable conditions of use. For example, a candle is considered an article and the chemical substances are exempt from registration; however, if the candle is scented, the substance making up the fragrance ARE intended to be released. For more information, please refer to the ECHA Guidance on Substances in Articles. Based on the information in this guidance, it is our opinion that substances in nonstick cookware and other coated articles are not intended for release, and therefore do not require registration under REACH.

The Registration, Authorisation, and Restriction requirements of REACH impact EU-based article manufacturers, while non-EU based article manufacturers must comply with applicable Restrictions and the SVHC notification requirements.

Registration

All chemicals substances used in coatings formulations must meet the registration requirements by 31 May, 2018. Registration is required for substances or monomers of polymers imported or manufactured in quantities equal to or greater than one (1) metric ton per year (1 metric ton = 2205 pounds). Registration must be completed by the EU manufacturer or importer of the substance. For importers, the registration may also be completed by an EU-based representative acting on behalf of the non-EU manufacturer. (Such a representative is termed an “Only Representative”.)

SVHCs and Authorisation

Authorisation is a multi-step process that begins with the identification of Candidate Substances of Very High Concern (SVHCs) for Authorisation. For this reason, SVHCs are also known as candidates for authorisation. Once listed, SVHCs can continue to be used; however manufacturers must notify customers if their product, including articles, contains an SVHC > 0.1%.

Once a substance becomes an SVHC, member states can then nominate the substance for authorisation. Under the authorisation process, manufacturers, importers, and/or users must request “authorisation” from ECHA to continue using the substance after a specified sunset date. If authorisation is not granted, that specific use of the substance in the EU is prohibited. Authorisation is limited to the scope of the request, so an SVHC could be authorized for use in one application, but not another.

Restriction

The restriction provisions of REACH differ from those for authorisation in two important aspects. First, the use of a substance can be restricted without first being listed as an SVHC (because SVHCs are candidates for authorisation). Second, once use of a substance is restricted, it cannot be subsequently authorized for that use. ECHA has consolidated all previously existing chemical restrictions under this section of REACH.

REACH – Turkey

In 2008, Turkey adopted its Regulation on the Inventory and Control of Chemicals which is similar to the EU REACH regulation. Also known as Turkish REACH, the regulations require manufacturers and importers of substances on their own or in preparations over 1 tonne per year to notify authorities. As with REACH, articles are exempt from these notifications. However, unlike the EU regulation, there is no requirement to register substances intended for release from articles. The Turkish regulation also does not contain provisions for restricting the use of substances.

 

 
 
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