Readers' letters

29 June 2009 00:00  [Source: ICB]

One reader highlights the frustration of a US plastic resin producer in trying to undertand and deal with the EU's Reach regulations. We welcome you to share your thoughts

I read Will Beacham's article "Industry rages at ECHA" in the June 8 issue of ICIS Chemical Business and basically agree.

I work for a petroleum hydrocarbon resin manufacturer in the US, which has a European operation that serves as our Only Representative (OR).

Our OR had various problems getting information. We have had several downsizings these past few years and simply don't have the resources and cash to really do all that Reach (the European chemical management system) seems to require.

I've read a lot of materials and still cannot understand the requirements of Reach. This is what most frustrates me - nothing is black and white.

We make polymers, but the constituent monomers have to be registered? Why is that? Table salt is quite different than sodium and chlorine.

When they want usage/exposure information, is it for the finished resins or the raw materials since it is the raw materials we have to register?

We export very little product to Europe directly, but our products end up there.

For example, we manufacture a resin that is sold to a distributor. The distributor sells the resin to an adhesive manufacturer. The adhesive producer makes its adhesive, some of which may end up in Europe. How do we ever trace that kind of thing?

We basically have no data on how much of our customers' finished products end up in Europe. Also, we don't know their formulations - how much resin is used in a product.

If we refuse to cover customer poundages in our registrations, what can the customers do to still be able to move their products into Europe ?

What if a customer starts to make something in the future using our resin that starts getting shipped to Europe? What would our responsibilities be?

We also purchase coproducts/by-products as raw materials from the petrochemical industry. But these come and go depending on industry specifics.

As a result, we have to change formulations to keep producing. What are the Reach consequences of this kind of thing?

Lastly, there is one CAS Number used by multiple suppliers for various "resin forming" raw materials. These materials can be quite chemically different but still share the same CAS Number.

What are the Reach consequences if we switch among these in product formulations?

Paul Sauers, Allison Park, Pennsylvania, US

Editor's note:

We thank Mr. Sauers for brining to light the frustrations felt about Reach, especially among smaller chemical producers.

We have referred him to Reach expert Chris Eacott, managing director of UK-based consultancy
Stewardship Solutions, and member of the ICIS Chemical Business Editorial Advisory Board.

By: Joseph Chang
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