FUCHS & REACH
Since June 1, 2007, a new European chemicals regulation known as REACH has been in force.
FUCHS has established a dedicated expert working group to ensure that all necessary steps required by REACH legislation are taken. At the same time, we are cooperating closely with our suppliers of raw materials and intermediates. We want to assure you that FUCHS is giving this matter all the required professional attention to ensure compliance with the strict requirements of the new legislation within the set deadlines. We are making every effort to ensure that our products will remain available in the future. Currently, we do not anticipate discontinuing any of the products you are using due to this regulation.
We also believe that a clearer understanding of REACH can be supported by explaining some of the key terms, which we have prepared for you below.
Agency
The central agency for REACH within the EU is called ECHA (European Chemicals Agency), located in Helsinki.
Authorization
A specialized approval process by the agency for certain hazardous substances (e.g., carcinogenic, mutagenic, etc.). Authorization is granted to the manufacturer or importer. Our company does not use substances in its products that require authorization.
Objectives of REACH
The main goal of REACH is to improve the protection of human health and the environment from risks associated with the use of chemical substances.
Chemical Substances
REACH covers all individual substances manufactured or imported into the EU in quantities above 1 tonne per year. FUCHS both purchases and manufactures some substances and, accordingly, fulfills all REACH obligations. Specifically, FUCHS will pre-register and register all substances it produces itself.
Preparation (Mixture)
A preparation is a mixture of several chemical substances and, as such, does not require pre-registration or registration under REACH.
FUCHS Products
FUCHS products are mixtures of multiple substances and are therefore considered preparations under REACH terminology. The formulation is company know-how and therefore classified as confidential information. For this reason, our company does not disclose the composition of individual preparations to its customers.
Use
Together with substances, “identified uses” must also be registered. A substance may only be used within the scope of these registered uses. Risk mitigation measures apply only to these registered uses.
Registration
REACH legislation requires the registration of nearly all chemical substances within a set timeframe. Without registration, substances may not be placed on the market, following the principle: “No data – no market.”
Registration Obligation
Under REACH, the entity placing a chemical substance on the EU market has the registration obligation – i.e., manufacturers or importers bringing substances into the EU from non-EU countries. Manufacturers of mixtures or end users (so-called downstream users) are not subject to registration obligations. However, they are required to provide information within the supply chain. You, as our customer, are in most cases considered a downstream user.
Exemptions
All substances are subject to pre-registration or registration unless explicitly exempted. Examples include certain natural substances or substances regulated by stricter EU legislation (e.g., food, biocides, pharmaceuticals, etc.).