REACH: Challenges in the Chemical Distribution Industry

February 15, 2013

Although they play a major factor in the chemical supply chain, chemical distributors are often responsible for not only the distribution of chemicals, but also provide additional services such as repackaging, mixing, compounding and blending. As a result, chemical distribution companies are affected by REACH and CLP, along with any other regulatory requirements.

Many distributors are also importers, which creates similar problems as those faced by manufacturers when dealing with compliance issues in regards to REACH and CLP.  

Fecc (the European Association of Chemical Distributors) developed a guidance document in 2011 which outlines what is required by registrants while concurrently providing recommendations in a clear manner. The purpose of the 2011 document is to raise awareness and to provide assistance to members when necessary in order to ensure that all members comply with REACH regulations.

A survey conducted by Fecc in 2013 highlighted that 140 registration documents have been submitted; the majority intending to buy letters of access. 63 of 140 dossiers were registered in 2010. Although it was predicted that more distributors would be submitted this year, the 2018 registration deadline will likely see more from the field, specifically with more SMEs; however, the biggest hurdle is the access costs to data generation and data access.

When conducting risk management assessments in order to meet the objectives of safe use set by REACH, distributors may find the extended safety data sheets - or exposure scenarios - provide too much information.

The REACH objectives do not solely apply to substances, but to mixtures as well. Distributors receive information from a diverse range of suppliers of the same substance, which force distributors to provide a unique and consistent set of information for their client base.

The Fecc, alongside other DUCC members, have provided documentation which provides options on converting substance data into safety data sheets for mixtures. In addition, the Fecc will address authorization, harmonization of information for poison centers, C&L Inventory challenges as well as publishing the REACH review.

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