A Nottinghamshire-based manufacturer is urging action in advance of the introduction of one of the most significant pieces of legislation to impact on the surface coatings industry in recent years.
Dacrylate, based in Kirkby-in-Ashfield, manufactures high performance protective coatings. The company says that the impact of the REACH 2018 regulations, which concern the Registration, Evaluation, Authorisation and restriction of Chemicals, should not be underestimated.
Designed to protect people and the environment from the effects of exposure to harmful chemicals, REACH 2018 will require manufacturers or importers of substances to register them with a central agency if they are to continue to supply them within the EU.
2018 will see the third and final phase of the legislation implemented and David Eames, technical director at Dacrylate, says this is where many ink and coating manufacturers will feel the effect. He said: “The Tier #3 implementation of REACH will extend the scope of the legislation to sales or imports of substances into the EU of more than 1 Tonne per year. As the cost of registration can be very high, it is likely that the production of some very low volume products will no longer be cost effective and they may well disappear from the market. This could present a significant issue for manufacturers that are not prepared and haven’t thought about product substitutions.”
The BCF estimates that only around 7,000 substances have been registered so far, with numbers expected to increase to somewhere between 25,000 – 50,000 by 2018. Not only does this dramatic increase look likely to create an administration overload, there are also concerns that some product registrations simply won’t be completed in time. Planning, scheduling and conducting the necessary substance testing, together with completing the hazard assessment and documentation for safe use can currently take almost three years.
Eames added: “2018 really isn’t very far away and the industry needs to start thinking proactively. At Dacrylate we are committed to supporting the principles of REACH and have already started building a REACH inventory with our suppliers. The next step will be working with our in house Research and Development facility to identify how our products can be modified and where substitutions may have to be made. I would urge other coating and ink manufacturers to do the same. As Downstream Users we rely on registrations being submitted further up the supply chain and this puts us at even greater risk.”
The deadline for the registration of substances under Tier 3 is 1st June 2018.