REACH Regulation 1907/2006 Registration, Evaluation, Authorisation and Restriction of Chemicals
The Regulation 2006/1907/EC concerning the registration, evaluation, authorisation and restriction of chemicals (REACH) entered into force on 1 June 2007.
The legislation should ensure a high level of protection of human health and the environment as well as free movement of substances. Manufacturers and importers of substances in quantities of 1 tonne or more shall submit a registration to the European Chemical Agency.
This affects virtually all-chemical substances placed on the market (produced and imported), including refrigerants, such as HFCs. The key responsibilities are for producers and importers, but downstream users will be involved, as certain information has to be communicated up and down the supply chain.
For all existing substances (substances listed in the EINECS list -European Inventory of Existing Commercial Chemical Substances), including all the commercial HFCs these substances should have been pre-registered during the period 1 June 2008-30 Nov 2008. Pre-registration is a simple process requiring limited information and each legal entity that produces or imports an existing substance should have considered pre-registration.
Registration: Deadlines for completing the dossier
|1 June − 30 Nov 2008
¹ classified as very toxic to aquatic organisms and may cause long-term adverse effects in the aquatic environment (R50-53) in accordance with Directive 67/548/EEC
² classified as carcinogenic, mutagenic or toxic to reproduction, categories 1 and 2, in accordance with Directive 67/548/EEC
Following pre-registration, a dossier has to be prepared providing a range of information about uses, toxicology, and environmental effects for each substance. The Dossier must contain a Chemical Safety Report and Exposure Assessment. Specific Exposure Scenarios may be required for some substances, specifically chemicals classified as Dangerous, such as Anhydrous Hydrogen Fluoride (HF). Where appropriate Safety Data Sheets must be expanded to complement the REACH dossier.
The deadline for Registration depends on the tonnage that each legal entity (company) produces/imports and the classification of the substance. For HFCs with tonnages above 1000 tonnes per company (legal entity) then registration is by November 2010.
REACH requires registration of individual substances (unless produced as a mixture), and this means that the components of blended refrigerants (400 and 500 series, eg R-410A) need to be registered. Under REACH a blended refrigerant is a preparation and these do not need to be registered, just the individual components.
Virgin HCFC refrigerants, including the drop-in service refrigerants, will be phased out by end 2009 under Regulation 2037/2000
on substances that deplete the ozone layer.
Distributors who source refrigerant from companies that produce in the EU or import refrigerants do not need to pre-register and/or register their substances, but they will need to ensure that the sources they purchase from have pre-registered/plan to register the refrigerant components.
Any importers of refrigerant (or refrigerant component) will need to comply with REACH.
The treatment of recycled refrigerants (HFCs and HCFCs) under REACH needs further consideration, and further information will be provided when available.
Recycled HCFCs can continue to be used under Regulation 1009/2009 (which replaces 2037/2000
from 1 Jan 2010), currently until end 2014. However it is anticipated that HCFC 22 will be the dominant recycled HCFC.
Until registration of a substance(s), reclaimers of refrigerant should have pre-registered the substance(s) in order to remain in compliance with REACH, if they reclaim above 1 tonne annually.
Mexichem Fluor Activities
Mexichem Fluor plans to be fully compliant with the REACH requirements and has pre-registered and will then register the refrigerant components it produces or imports.
As Mexichem Fluor will stop producing or importing HCFC 22 before the registration deadline, it is not required to register HCFC 22.
Mexichem Fluor has evaluated all its raw materials, identified any critical raw Materials, and has in place a process to contact suppliers to establish that they will be REACH Compliant (initially by pre-registration these substances).
Manufacturers and importers are encouraged to collaborate to the preparation of registration dossiers, by sharing information on hazard and exposure for the chemical substances. The formation of voluntary consortia will facilitate the information sharing.
Mexichem Fluor is participating in the Fluorocarbon consortium, a voluntary consortia to develop the registration dossiers for HFCs and other refrigerant components including HCFCs. See www.fluorocarbons.org
for further information about EFCTC activities for REACH or contact the Fluorocarbon consortium secretary at firstname.lastname@example.org
In particular companies that intend to reclaim HCFC 22 may want to contact the Fluorocarbon consortium secretary at email@example.com
'If you need further information about Mexichem Fluor REACH activities please contact us at the following e-mail address firstname.lastname@example.org