REACH
The European Parliament and Council (EPC) directive No. 1907/2006 (generally called REACH) relates even to the products of CHEMOTEX Decin a.s. company.
Until 30th November 2007 – what was the deadline for the re-registration according to the REACH directive – our company passed on about 100 re-registrations to the ECHA agency. On the basis of these re-registrations CHEMOTEX Decin a.s. uses the grade period for the existing agents registration in compliance with the REACH directive.
The agents coming to the market – both themselves and as a compound – which are subject to the registration obligation are going to be registered in accordance with the corresponding production amount within the conditions stated by the REACH directive.
The REACH directive does not pose any risk for CHEMOTEX Decin a.s. in conjunction with a possible inability to fulfill its requirements. Hence, there is no intention whatsoever in planning passing any of currently produced agents out of our assortment. If this kind of decision is made in the future, our customers will be acquainted with this fact in advance and they will be given an alternative solution if applicable.
Subsequently, the company collects information from its suppliers regarding the registration process of purchased chemical agents and provides them further to its final customers – users.
The REACH directive implementation as well as its compliance in the company is really complicated and hard process from the administrative point of view.
The complicacy and seriousness of the process as a whole shows in the time when the company did not receive all of the relevant data concerning that agents, for which the term of registration has already forfeited and which are bought and further processed for a chemical syntheses, compound preparation or redistribution. As relevant information about a chemical agent is not regarded y the mere act of registration and registration number statement, but also extended Safety Data Sheet (SDS) in compliance with the REACH directive including corresponding exposure scenarios. These are only applicable, if there is a need related to any agent to work out a report about chemical safety.
These all actions are in place in spite of the fact, the first deadline for the chemical agents registration has already passed by at 30th November 2010. This already outdated chemical agents registration concerns that agents produced in amount of 100+ tons a year, agents posing the risk for the environment produced in amount of 100+ tons a year and so called CMR agents in amount 1+ ton a year.
The issue of information share has also been discussed at European Chemical Industry Council (CEFIC), which brought its opinion at the current situation to public (see link below):
Besides the obligations ensuing from the REACH directive, the company also does fulfill the obligations ensuing from the Regulation (EC) 1272/2008 about Classification, Labelling and Packaging of chemical agents and compounds (CLP).
Contact person in REACH matter: Contact person for CLP:
ing. Jaroslav Písek Dana Kopřivová
tel.: +420 412 709 270 tel. : +420 412 709 224
mobile: +420 602 225 508 mobile: +420 724 859 803
e-mail: jaroslavpisek@chemotex.cz e-mail: danakoprivova@chemotex.cz
