REACH — Frequently Asked Questions
How is Arakawa Europe organized and prepared for REACH implementation?
Will any ARKON* resins be subject to authorization?
How will the downstream use of the products we receive be addressed during the registration process?
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How is Arakawa Europe organized and prepared for REACH implementation?
Arakawa Europe is preparing for the implementation of REACH through the REACH implementation program management office of Dow. This central unit of one of our shareholders identifies financial and people resource needs, assesses business impact and orchestrates the development of work processes, IT needs and internal and external communication materials. Arakawa Europe will be accountable for the implementation of REACH compliance requirements. Dow’s corporate expertise and service functions will assist the business.
Arakawa Europe has built up expertise in REACH requirements, systems and processes through Dow’s intimate involvement in advocacy, input to legislative texts, development and testing of guidance documents of IT tools (e.g. IUCLID5), as well as involvement in pilot projects and impact studies.
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What are Arakawa Europe’s plans for pre-registration and registration of substances in raw materials and other components used to manufacture ARKON* water white hydrocarbon resins?
In the interest of business continuity, Arakawa Europe’s primary objective is to ensure that all substances that are components of ARKON resins or are used in manufacturing processes will be pre-registered and registered in accordance with REACH requirements and timelines. Therefore Arakawa Europe is working with Dow Olefinverbund GmbH, which manufactures ARKON resins, to ensure pre-registration and registration of substances in REACH relevant raw materials and other components that are manufactured in the EU or imported into the EU for the manufacture of ARKON resins.
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What does Arakawa know about Dow’s plans for pre-registration respectively registration of substances it manufactures and imports that are used in Arakawa Europe products?
At this time, Dow intends to pre-register all of the substances that it manufactures in the EU or manufactures outside the EU and imports into the EU including those used in Arakawa Europe products.
In addition, Dow anticipates that the majority of substances in its current product portfolio will be registered for a range of typical downstream uses.
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What are Arakawa Europe’s plans for communication of REACH compliance information in the supply chain?
Downstream users of chemicals will need certain information to enable them to fulfill their own REACH compliance requirements.
All relevant information that downstream users may need to fulfill their REACH compliance requirements will be provided via the updated safety data sheet, which Dow as the manufacturer will issue at the time of registration.
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Will any ARKON* resins be subject to authorization?
Polymers, including ARKON resins, are not subject to registration; however polymers may be subject to authorization under REACH when they are listed in Annex XIV. This Annex will be populated through a candidate list. Although the candidate list of substances subject to authorization does not exist yet, there is no reason to expect that ARKON water white hydrocarbon resins will be subject to authorization.
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Will you/your supplier publish the assigned pre-registration number after pre-registration with ECHA?
The pre-registration number is the mean of confirming to the pre-registrant that the pre-registration has been submitted successfully. There is no legal requirement to communicate the pre-registration number in the supply-chain (see also CEFIC industry preparation letter #9). The provision of a pre-registration number does not guarantee any future compliance with REACH or continuity of supply. The important REACH compliant statements to customers will be communicated efficiently on a product level by the supplier at the given point in time.
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How will the downstream use of the products we receive be addressed during the registration process?
Our supplier will be following the 'top-down' approach supported by CEFIC and its members. First, all down-stream uses will be identified internally, and then published by trade-product on a secure web-based portal. Each individual customer can then identify whether their specific down-stream use is covered, and if needed has the opportunity to submit additional uses via a specific form.
The downstream use is not required for the pre-registration process. The work process and IT tools to support this are currently being developed, and our supplier will be in the position to communicate on downstream uses in early 2009.
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* Trademark of Arakawa