The EU mandated that substances in quantities from 1000 metric t/a, substances from 100 metric t/a labeled as R50/53 and substances in quantities from 1 metric t/a with CMR 1 or 2 properties be registered by Dec. 1, 2010. Any company that failed to register could no longer sell that product in the European market.
The second deadline for REACH was June 1, 2013, in which other substances in quantities from 100 - < 1000 metric t/a were required to be registered. June 1, 2018 is the deadline for substances in quantities from 1 - < 100 metric t/a.
The printing ink industry is impacted by REACH, and companies have taken a proactive stance on the issue. In particular, Flint Group has reported that it has provided all registration dossiers for the 100 to 1.000 tons p.a. registration tonnage band to the European Chemistry agency (ECHA), and has already received all 2013 registration numbers from the authority.
To say that REACH is complex is an understatement. Flint Group noted that its REACH registration dossiers consist of up to 2.500 pages.
Not surprisingly, the major European chemical manufacturers have announced that they have complied with the 2013 REACH deadlines. For example, BASF has reported that it has successfully pre-registered all substances manufactured in or imported into Europe, and Clariant, Wacker and Croda are among the European chemical companies that have also stated they have registered their products. In the U.S., Dow Chemical announced it has submitted its dossiers.
For larger corporations and volumes, the cost of REACH can be spread out. The REACH process is costly, and the concern is that the 2018 deadline will force companies to decide whether to go through the registration process for smaller batches of chemicals or simply withdraw these products from the marketplace. In its analysis, Flint Group expects some raw materials to “disappear from the market.”