REACh implemented – DyStar® successfully fulfilled its registration obligations”
By the end of May, 2018, the transitional periods are completed. DyStar has successfully submitted its registration dossiers for all chemicals or monomers, produced or imported at a volume above 1 ton per year. We hence remain in full compliance with the obligation to register all chemicals in the appropriate tonnage band by May 31st, 2018.
The number of registration dossiers submitted for both phase-in and non-phase-in substances is now about four hundred fifty in total. As in the past, DyStar actively contributed as Lead Registrant to the efforts of the European Textile Dyes Consortium. DyStar’s expertise and the archives of existing toxicological and eco-toxicological test reports have been basis for all REACh activities.
Interview with Dr. Clemens Grund, Senior Director Global Technology & Ecology, DyStar
The primary REACH registration phase has come to the end. Whatis your conclusion so far?
It has been a challenge to learn how to cooperate within the consortia, SIEFs, with competitors, non-EU data holders, authorities, testing institutes, NGOs and others involved in the complex processes. Negotiations with SIEFs, representing several hundreds of (potential) registrants, are not always quick and easy to handle. In the beginning we started with the registration of some rather big volume items, but at the end the handling of dozens of small, but nevertheless important, items all in parallel needed to be managed. The workload at the testing institutes and their time frames have been also very challenging. The registration software tool, IUCLID, has been updated several times and became more and more complicated.
Now the work is done?
ECHA expects not only the LEAD Registrants but those submitting member dossiers as well to update their dossiers on a regular basis, preferably every six months. In other words: the more dossiers you have submitted, the more you are working on updates. This needs to be managed in parallel to the registration of additional new items. And the more complex the database becomes by new obligatory entries, the more challenging and time-consuming the IUCLID dossier updates are. And additionally, ECHA will more and more concentrate on the evaluation of submitted dossiers. Based on experience gained so far with the evaluation of some high-volume chemicals a lot of requests for either additional testing and/or more detailed information on several already submitted test results can be expected. So not the submission of new dossiers but the optimization of the huge number of existing dossiers will keep us busy.
Has DyStar restricted its portfolio due to REACH?
As already communicated during the past years, DyStar decisions on portfolio setup have never been driven by REACH registration obligations! We registered all our specialties, based on the required tonnage bands. We will be able to supply our EU customers with all products in the volumes they are used to purchase from DyStar.
What about the progress of REACH outside Europe?
There are other countries in the world that already announced the publication of a REACH-like legislation, e.g. Turkey, China, India and Korea. In 2017, Turkey has published their “Turkish REACH”, KKDIK. The pre-registration phase started already and will close end of 2020. Even a lot of details are not yet clearly communicated by the Turkish authorities, industry is requested to start immediately due to the very short timeline for final registration. Due to the importance of Turkey for both textile dyes and chemicals business for DyStar, this KKDIK is the most challenging project out of the existing REACH-like legislations.
What is your conclusion so far?
DyStar contributed to the REACH registration process from the very beginning, especially also as member of the European Textile Dyes Consortium. Registrations have been handled successfully within the given timeline. The past about ten years have been a huge project for DyStar and the colleagues who have been involved.
Everybody has to be aware that European REACH did not end at May 31st, 2018! For all the dossiers that have been submitted the update obligations have to be fulfilled. ECHA will go deeper into the evaluation of all the dossiers, so that at least intense discussions with the experts will go on.