REACH is the new single regulatory system for chemicals management in the European Union. REACH was published on December 30, 2006 and entered into force on June 1, 2007.
REACH requires EU manufacturers and importers of substances into the EU, (at one tonne or more per year per legal entity), to disclose information on the properties of their substances including the risk to humans and the environment associated with use. Information on appropriate risk-reduction measures must also be provided.
The pre-registration phase for substances ceased on December 1st 2008. Depending on substance volume and classification, registration deadlines are November 30, 2010; May 31, 2013 and May 31, 2018.
MEGlobal, through The Dow Chemical Company’s* (Dow) REACH implementation program office, is fully prepared to ensure compliance with the legislation for its products based on monoethylene glycol and diethylene glycol. Dow’s corporate expertise and service functions will assist MEGlobal in this regard.
In the interest of business continuity, MEGlobal's primary objective is to ensure that all substance components of our products that require registration are covered in the pre-registration process. This has been completed successfully within the assigned timeframe. MEGlobal is working with its suppliers to ensure pre-registration and registration of substances in materials it purchases. Our Product Information Sheet contains the milestone in this regard.
As is the case for pre-registration, MEGlobal will ensure REACH registration compliance for its products based upon monoethylene glycol (MEG) and diethylene glycol (DEG), and within the timetable applicable to the import tonnage. The registration dossiers will include the range of supported end uses for completion of the chemical safety assessment and chemical safety reports. MEGlobal is working closely with its customers to obtain details of their uses to fulfill this need.
MEGlobal plans to adopt the standardized format developed by CEFIC to facilitate communication about downstream uses and our intentions to ensure substance registration. We anticipate beginning to use this format for information exchange with customers when sufficient technical guidance regarding required information exchange related to downstream uses is available from the EU authorities and after appropriate discussions have taken place in the substance SIEF’s (Substance Information Exchange Fora).
Please note that users of chemicals also have the obligation to inform their suppliers about their intended downstream uses. They should provide the supplier with sufficient information to allow completion of the chemical safety assessment and chemical safety report particularly exposure information.
Pre-registration has been completed. Registration plans are already well underway in conjunction with our substance consortium members and registrations will be completed based upon the appropriate tonnage bands.
For products classified as hazardous, the registrant (manufacturers and importers) needs to demonstrate that they are safe to human health and the environment. To do so, information has been collected about the handling and use of products and the potential for exposure to humans as well as to the environment. These identified downstream uses are described using the descriptor system as lined out in the REACH guidance document for chemical safety assessments, Chapter R.12: Use descriptor system.
The communication of downstream uses via spreadsheets for Ethylene Glycol and Diethylene Glycol is part of an on-going strategy to make MEGlobal customers’ roles in complying with REACH easier. The downstream use spreadsheets allow customers to look up Downstream Use (DU) information for products they purchase from MEGlobal in Europe. Downstream uses (DUs) and downstream uses exposure scenarios (DU-ESs) displayed in the spreadsheets are identified uses that will be assessed for registration. This may include that additional risk reduction measurements need to be applied. Not all identified uses will necessarily become registered uses.
When a substance has been registered, the uses that have been registered and exposure scenarios with the respective safe handling procedures will be incorporated into the suppliers material safety datasheets. Please note that after the official registration deadline, customers are only allowed to handle the product under condition as described in the material safety datasheets.
Substances manufactured by MEGlobal outside the EU, purchased by non-EU customers outside the EU, then exported to the EU may be covered by our Only Representative (OR) assigned to cover Dow imports of the same substance. The Dow Chemical Company has established an Only Representative Trustee (ORT) as an independent third party to administer all business confidential data. This offers our non-EU customers the opportunity to cover the REACH registration obligations of their EU importing customers via the respective Dow REACH registration so that they can continue their sales in the EU. Contact the REACH customer focal point to learn more.
For extensive information regarding the legislation, please review the
EU website, or see
Dow’s REACH Internet site.
For questions relating specifically to MEGlobal’s product portfolio, please contact our REACH customer focal point.
*MEGlobal is a 50/50 joint venture between The Dow Chemical Company and Petrochemical Industries Company in Kuwait.