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REACH

A brief overview from LEONHARD KURZ GmbH & Co. KG


Current: June 2007
The purpose of this document is to give our and could previously be marketed without
customers a brief overview of REACH and restriction. Even substances that were previ-
the related activities at KURZ. ously considered to be polymers, but later
not (so-called No Longer Polymers), could
KURZ is wholly committed to the obligations
still be sold and were considered old sub-
arising from the objectives of REACH and its
stances.
implementation for all affected industry sec-
tors. The intention of REACH is to reverse the bur-
den of proof and eliminate the inconsistent
1. What is REACH? treatment of so-called old substances and
new substances:
REACH is the new EU chemicals regulation • Manufacturers and importers of old sub-
that will serve as the chemicals legislation stances will be obligated to perform a hazard
EU-wide. assessment.
The name derives from: • Substances requiring mandatory regis-

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Registration tration, and substances not registered by the

Evaluation of Chemicals manufacturer will no longer be allowed to be


marketed. Processors will not be allowed to
Authorization
use them either.

2. Why REACH? 3. Timeframe for REACH


The main objective of REACH is to protect
REACH came into force on 1 June 2007 and
human health and the environment.
provides the following timeline:
There were found to be weaknesses in this During the first 12 months, the agency in
regard in past chemical policies, in particular Helsinki will be made operative.
as a result of information gaps in the area of
From 1 June 2008 pre-registration of all
„old“ chemical substances: While the previ-
substances according to REACH will com-
ous system required the comprehensive
mence. Thereafter, various transitional peri-
evaluation of so-called „registered substanc-
ods can be utilized for old substances (de-
es“ (these are substances introduced since
pending on quantity and potential hazard).
September 1981) with regard to their hazard
This pre-registration period ends on 1 De-
to the environment and health, the so-called
cember 2008.
„old substances“ (substances introduced
prior to September 1981) were never subject The substance can continue to be marketed

to such comprehensive testing regulations. until the relevant transitional period expires.
In the absence of pre-registration, the sub-
These old substances were taken up in the
stance will be regarded as a new substance
EINECS list (European Inventory of Exist-
and must be registered immediately.
ing Commercial Chemical Substances)
4. Registration, evaluation and Evaluation of the submitted material data is
approval performed by the European Chemicals Agen-
cy. Where the data suggests an increased
The following transitional periods apply for hazard to humans or the environment, the
the registration of „old substances“: agency can arrange for further studies.

1 December • Substances
2010 > 1,000 t.p.a
(three-and-a- The mandatory authoriza-
• Carcinogenic, mutagenic or repro toxic
half years after tion requirement applies to
substances of category 1 and 2
coming into substances whose proper-
(so-called „CMR substances“)
force) ties give particular cause
> 1 t.p.a
for concern: carcinogenic,
• Substances with the classification R 50/53 mutagenic, repro toxic/
(„very poisonous for aquatic organisms“)
embryotoxic and/or par-
> 100 t.p.a
ticularly environmentally
hazardous substances will
1 June 2013 • Substances
be subject to an approval
(six years after > 100 t.p.a
process by the new EU
coming into
authority;
force)
Objective: To ensure the
substance is only utilized
1 June 2018 • Substances
> 1 t.p.a in applications with a mini-
(eleven years
mal or reasonable risk to
after coming
humans / the environment
into force)

Safety data sheet:


Regardless of priority level, details in regard The SDS remains the key element with regard
to hazard potential, use and risk management to handling/usage/safety issues associated
measures will need to be provided when reg- with substances and preparations throughout
istering each chemical substance. the product life cycle. It is anticipated that the
SDS will be extended by an annex containing
a substance safety assessment for the ingre-
dients in relation to the specified usages.
5. What measures is KURZ Our preliminary results have shown that
taking in preparation for the entire range of polymers that we use
REACH? does not fall within the scope of the REACH
regulations. As we predominantly use raw
• Participation in the public Internet consulta- materials from the polymer group in the
tion on the first draft of the REACH Regula- manufacture of our stamping foils, we do not
tion anticipate any restrictions in this area.
The range of substances classified as CMR
• Participation in the resolution of the „En-
(carcinogenic, mutagenic, repro toxic) are
ergy and Environment“ committee of the IHK
not relevant to KURZ either at present since
(German Chamber of Commerce) on the new
we do not employ these CMR classified
European Chemicals regulation
substances in the formulation of our foil prod-
• Participation in a project of the Bavarian
ucts, as evident from the information
Ministry of the Environment to access the
provided by our raw material suppliers.
impact of the draft regulation on the manu-
Our „STAMPING FOIL“ product itself is
facture of highly innovative products
considered a product according to the
• Close contact and exchange of information
REACH Regulation and therefore does not
with material suppliers and manufacturers
need to be registered.
with regard to a successful implementation of
REACH
Should you have any further questions,
• Intensive evaluation of the impact of please feel free to call one of your regular
REACH at KURZ prior to its coming into contact persons in our sales departments.
force, for example:
• Preparation of a list of all materials
processed to produce our products, the
suppliers of those materials, and the avail-
able information and data for them
• Evaluation of the collected data, in par-
ticular with regard to future purchasing
risks and, where applicable, the registra-
tions that would be required.

LEONHARD KURZ GmbH & Co. KG


Schwabacher Strasse 482
© KURZ 2007 95002113.06/07.1

90763 Fuerth/Germany
Phone: +49 911 7141-0
Fax: +49 911 71 41-357
Internet: www.kurz.de
E-Mail: sales@kurz.de