The Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) has shaped the regulatory landscape of the market for chemicals at every life cycle stage. The concept of REACH Compliance not only affects chemical substances on their own, in mixtures or in articles but more importantly, it impacts the manufacturing processes, the placing on the market as well as the use of chemicals. The REACH Regulation lays down a common set of specific duties and obligations on the actors in the supply chain such as manufacturers, importers and downstream users. Those who manufacture, import or use substances on their own or in mixtures are not only responsible for the management of risks associated but also for the communication of relevant information and recommendation about risk management measures to allow safe use.
As the global market leader in chemical distribution, Brenntag connects suppliers and customers from all over the world by an integral approach and with industry expertise and a professional organization strives to create value for its business partners. By nature of the products it sells, Brenntag is acting in a highly regulated market in global, regional as well as local respect. Brenntag is fully committed to responsible care and responsible distribution and it is one of its key business principles to fully comply with all regulatory requirements, including but not limited to those defined by Europe’s REACH Regulation. The value chain along the daily business operations of our European entities encompasses various chemical and physical activities. This implies that Brenntag is affected by REACH in all aspects covered by REACH roles:
- As an importer and manufacturer
- As a Downstream User through its Blending Business Service activities or when executing processes like de-bulking, re-filling or re-packing
- As a Distributor Brenntag is affected by REACH when it is executing basic activities like the purchase (within EEA), storage and sale of chemicals
Brenntag serves its business partners by executing its activities in a compliant and efficient way. To this end Brenntag dedicates regulatory experts and resources in every region of its European business segment. At the same time this team of experts ensures Brenntag’s compliance with REACH in all dimensions of its own business processes. By that Brenntag is enabled to tap on broad expertise and knowledge base with regards to similar processes of its business partners.
The last registration deadline for existing substances manufactured or imported in the EEA at or above 1 ton per year is 31 May 2018. With an estimated 25.000 to 50.000 substances to be registered keeping this last deadline will be a challenge for all stakeholders active in the chemical industry.
The key features of the 2018 Registration Deadline having repercussions on the chemicals market:
- Many registrants will have limited/no experience in registration
- The Substance Information Exchange Forums (SIEFs) will be much smaller with sometimes even only one participant
- There will be less information available
- Bottlenecks in the availability of testing service providers
- Commercial decision for registration is made under imperfect information conditions
How does Brenntag cope with these challenges?
- Brenntag has internal expert team that has submitted several registrations in the past
- Given a proven business opportunity, Brenntag with assistance of external service providers would be able to take the position of Lead Registrant
- Brenntag has access to service providers that are capable of collecting and generating needed data
- Brenntag has secured access to testing service providers
- Brenntag is continuously challenged to take decisions under imperfect information conditions