“REACH Compliance continues to be a DyStar priority for substances both manufactured in and imported into the European Economic Area (i.e. the EU member states including Norway, Iceland and Liechtenstein).”
“DyStar is prepared to meet the challenges of REACH compliance”
With 12 months remaining before the May 2018 REACH registration deadline, DyStar is actively working to complete its registrations. Even though we have submitted more than 150 dossiers over the past 3 years, the remaining workload is considerable. However, DyStar has successfully submitted its registration dossiers to the European Chemicals Agency (ECHA) for more than 95% of the important dyes and basic chemicals in the tonnage band of above 10 tons. Therefore, we are on schedule to comply with the obligation to register all chemicals in the appropriate tonnage band by May 31, 2018.
The total number of registration dossiers submitted for both phase-in and non-phase-in substances exceeds 200. As in the past, DyStar actively contributed as the LEAD registrant of more than 50 dyes toward the efforts of the European Textile Dyes Consortium. Our expertise and the archives of existing toxicological and eco-toxicological test reports have been immensely valuable to this endeavor.
Interview with Dr. Clemens Grund, Senior Director Global Technology & Ecology, DyStar
Tell us about your experiences with the REACH registration process over the past three years.
We have become adept at organizing the information required for a successful registration – beginning with the appropriate registration sample, the selection of the testing institutes and the handling of all information required for a full dossier. These steps have become routine for us. But the registration software tool, the IUCLID, poses multiple challenges. The program has undergone several updates, each time presenting new obligatory fields, plug-in tools or program checks. This can make it difficult sometimes to create new dossiers and even harder when existing ones are being updated.
But the end of the registration phase is fast approaching so why the updates?
ECHA expects not only that LEAD registrants update their dossiers on a regular basis; member registrants need to as well – preferably every six months. In other words, the more dossiers one submits, the more updates there are to work on. This needs to be managed in parallel to the additional registration of new items. Further, the more complex the database gets, with new obligatory entries added every few weeks, the more challenging and time-consuming the IUCLID dossier updates become.
Will DyStar register all its products under REACH?
DyStar and its team of experts are working diligently on the dossier preparation work for IUCLID. We are quite optimistic that we will successfully submit dossiers – on time – for all chemicals that require registration. But we must keep in mind that the requirement is limited to only chemicals that are produced in or imported into the REACH area in quantities exceeding one ton per year.
What about the progress of REACH outside Europe?
There are other nations outside of Europe that have already announced the publication of REACH-like legislations, e.g. Turkey, China, India and Korea. Turkey has just postponed their deadline for the pre-registration phase, whereas Korea is still in the process of updating their regulations to align with those of the European Union’s REACH. However, as yet, details on deadlines, formats and content are not available to us. We are certainly not complaining about these temporary delays from other countries though, because – at the moment – all our resources are focused on completing the EU REACH registrations.
What about downstream user information?
The information content of the IUCLID files and the Chemical Safety Reports created from their database, which are obligatory for all chemicals above ten tons per year, do contain a lot of useful information. Unfortunately, expert know-how is needed to understand the outcome.
Thus far, DyStar has not been affected by any chemicals classified as substances of very high concern (SVHC). This means that the listing under Annex XIV, the Authorisation List, has not impacted the company’s business. Backed by more than 150 years of experience in textile dyes and the success of our econfidence® program, DyStar will continue to be a sustainable and reliable partner to the textile supply chain globally.
Are there any final remarks?
For us to be in the safe situation we are right now, DyStar had to start contributing to the REACH registration process very early on. To peers and competitors in the industry that have yet to start, we would encourage them to do so at the soonest possible time because it will be difficult for latecomers to catch up and meet the deadline.
Everybody must be made aware that REACH will not end on May 31, 2018. For every dossier that is submitted, there is also the obligation to keep it updated in the system. It is also important to understand that ECHA is expected to conduct in-depth evaluations of the dossiers. This means that we will be seeing intense discussions among experts regardless of whether the existing data is sufficient for the evaluation of a respective chemical. In fact, post-2018, many companies might find themselves having to conduct additional chemical tests.