REACH

REACH (registration, evaluation, restrictions and authorisation of chemicals), the new EU regulation on chemicals, was adopted on 18 December 2006 and came into force on 1 June 2007. Whereas under the previous EU chemicals legislation, only new (post 1981) chemical substances needed to be registered, and risk assessments on existing chemicals were conducted based on a priority list, under REACH:

• Every substance manufactured or imported in the EU above 1 tonne must be registered by the entity that imports or manufactures it, unless it is exempt from registration. This applies to substances manufactured or imported by cement companies. Upstream substances delivered to the cement industry must be registered by the suppliers.
• Each separate legal entity within a group needs to fulfil the REACH requirements individually (e.g. individual registration or pre-registration of a substance). However, implementation of REACH can be coordinated at group level and registrations can be conducted jointly for the same substance. Although even in that case, certain information must be submitted individually, legal entity by legal entity.
• Substances present in articles are subject to notification if they are contained in the articles above 0.1% by weight and are either carcinogenic (1 and 2), mutagenic (1 and 2), toxic to reproduction, PBT, vPvB or endocrine disruptors or of “equivalent” concern (and if they are identified as such in a so-called “Candidate list”).
• There will be an obligation to communicate upstream (towards suppliers) and downstream (to customers) on substances by means of safety data sheets (SDSⁱ) and chemical safety reports as the case may be.
• Substances considered as particularly dangerous and entered into a list will be subject to authorisation and possibly to marketing and use restrictions
• The REACH Regulation applies in all 27 EU Member States.

The EEA joint committee adopted REACH on 14 March 2008 and hence REACH also applies in the EEA-EFTA countries Iceland, Liechtenstein and Norway. This means that legal entities in the EEA-EFTA countries are to be considered as EU manufacturers and importers and that they will also pre-register substances and take part in the pre-SIEFs and SIEFs.

Switzerland, the fourth EFTA member country, is preparing to adapt its own chemicals legislation to REACH.

Clinker is a substance (not an intermediate) and is exempt from REACH registration. It must be classified and labelled and an SDS must be provided. The classification & labelling (according to the new CLPⁱ Regulation) of all substances (including those below 1 tonne as well as dangerous substances not subject to registration) must be communicated to the European Chemical Agency Inventory by 1 December 2010 at the latest. CEMBUREAU can undertake this classification and labelling (C&L) notification on behalf of cement producers.

Cement is a preparation. As a preparation, cement is not subject to REACH registration. Cement must be classified and labelled. Because it is a preparation, no C&L notification to ECHAⁱ is necessary. An SDS, possibly with exposure scenario must be provided. The existing chromium VI restrictions continue to apply.

CEMBUREAU represents cement manufacturers in 28 European countries. One of its tasks is to give cement companies guidance on the implementation of EU legislation. As the new European chemicals regulation, REACH, is a rather complex piece of legislation, CEMBUREAU and Cimeurope created a REACH implementation website for CEMBUREAU members and their member companies, focusing on the REACH requirements specific to the cement industry. Access to the REACH implementation site is available to other persons interested for an annual subscription rate of €1,000 (excl. VAT).

A consortium will be put in place to prepare a joint REACH registration dossier (including chemical safety assessment, chemical safety report, exposure scenarios and guidance on safe use) for the following Flue dust from production of cement clinker (covering the EINECS entry "Flue dust, portland cement" with EC number 270-659-9). More information In addition, a third party representation service was set up by Cimeurope for all cement companies (legal entities) covered by CEMBUREAU membership. The aims of this service were to

• Keep confidential the identity of the legal entity and information provided by the legal entity during the pre-SIEF discussions and;
• Coordinate the pre-SIEF process with other involved potential registrants.

Latest news

REACH: proposed review of 91 substances under draft CoRAP

On 21 October 2011 the European Chemicals Agency (ECHAi) submitted its first draft Community rolling action plan (CoRAP) to the Member State Competent Authorities and the ECHA Member State Committee. Read more

REACH Regulation: consolidated version now available

A new consolidated version of the REACH Regulation (registration, evaluation, restrictions and authorisation of chemicals), containing all the modifications up until 5 May 2011, has been published on the Eurlex website. Read more

Potassium dichromate potentially subject to authorisation

The European Chemical Agency (ECHAi) has issued a draft recommendation for the inclusion of Potassium dichromate on the List of Substances Subject to Authorisation (Annex XIV of REACH). Read more

REACH implementation - exemption from registration for recovered substances

Earlier this month, CEMBUREAU issued a paper which explains how to use the exemption from registration for recovered substances under REACHi. This paper covers which conditions have to be fulfilled and which information is necessary. It also contains an annex with more detailed information on substances which are of importance to cement producers, namely: gypsum, fly ash, blast furnace slag, converter slag and iron oxide.

The paper is available from here

REACH evaluation: latest news

Following on from the first REACHi registration deadline of 30 November 2010, feedback on the testing plans entered with the registration dossiers is expected from ECHAi by December 2012 at the latest. Flue dust from the production cement clinker, calcium sulfate, blast furnace slag, fly ash and burnt shale were successfully registered by the deadline.  Read more

Portland cement clinker: multiple entries notified to C&L inventory

CEMBUREAU recently discovered that there are 31 “different” notifications of the classification and labelling (C&L) of Portland cement clinker to the ECHA’s C&L inventory. As readers may be aware, CEMBUREAU successful submitted, on behalf of its members, the notification of the C&L of Portland cement clinker in December 2010 (see December 2010/January 2011 Eurobrief). Many of the additional notifications are not well documented as some do not contain a classification, and some do not have any references for the classification.  Read more

Notification C&L Portland cement clinker successfully submitted

In mid December 2010, CEMBUREAU successfully submitted, on behalf of its members, the notification of the classification and labelling of Portland cement to the ECHAi inventory. Read more

REACH - ECHA deadline for completeness check on REACH registrations met

Registration numbers have been granted for 20,175 of the 20,723 dossiers submitted by the first registration deadline, resulting in a total of 3 483 phase-in substances being registered under REACHi. According to the REACH regulation, ECHAi had three months to perform completeness checks on all registrations for phase-in substances submitted in the last two months before the first registration deadline. Read more

More information