The European Plastics Converters (EuPC) in association with Polymer Comply Europe (PCE) held a dynamic REACH Workshop: The Plastics Industry State of play with practical examples on 17 and 18 March 2016 in Brussels. The two-day workshop brought together participants from across Europe representing all levels of the supply chain and included lively debates, wide-ranging presentations and a networking event.
The trade association of EuPC has been actively involved in the development of REACH and one of the goals of the workshop was to focus on key learnings from past challenges brought on by REACH. The two-day event was also an opportunity to keep SMEs in the plastics value chain up to date regarding the latest developments regarding REACH, including practical tools and solutions developed by EuPC to facilitate the fulfilment of REACH obligations. Indeed, the implementation of REACH has thus far covered the registrations of big and medium volumes chemicals, the first authorisations and restrictions, but there are new challenges ahead that will need to be faced.
Geoffroy Tillieux, EuPC Technical Department Director & PCE Regulatory Compliance Director opened the workshop on March 17th: “In order to be successful and manage raw materials in a strategic way, plastics converters, masterbatchers and their downstream users should early on identify the key substances that may be under scrutiny and should exchange information on their uses and exposure from the onset.” He presented the rights and obligations for the plastics supply chain. Dr Bernhard Mahlberg from the Institute for Industrial Research evaluated the impact of REACH on the affected industries and Austria’s economy, a report commissioned by the Austrian Federal Ministry of Agriculture, Forestry, Environment and Water Management.
Various aspects of REACH registrations were covered by industry experts such as Roger Van Der Linden, PlasticsEurope REACH Committee Chairman, who discussed the notifications of nanomaterials. The registration in 2018 and orphan substances were presented by Karin Van de Velde, Secretary General of the REACH Orphan Substance Consortium. Venelin Marinov, Advisor to the Bulgarian Association Polymers, explained the duties of importers and only representatives. Furthermore, Patrick de Kort of PCE demonstrated the example of the Plastics Exposure Scenario Tool (PESTOOL) developed by the plastics industry to best understand risk management measures.
Urban Boije, Policy Officer of the Unit Chemicals at DG Environment, began Thursday’s session on recycling and the circular economy by presenting the European Commission’s vision for integrating recycling within the circular economy. Maurice Funcken of Nissan discussed the challenges of recycling automotive applications in relation to the latest REACH developments. Closing the session, Eric Vandevijver from Inovyn/VinyLoop shared past experiences with application for authorisations for uses of soft PVC recyclates containing legacy DEHP.
The second day of EuPC’s workshop was dedicated to risk management options for substances and enforcement. Klaus Berend, the Head of Unit REACH at DG Grow presented how to implement REACH in a streamlined way, covering steps such as RMOA, Authorisation and Restriction. Klaus Berend declared: “The authorisation process has proven to improve safety and encourage substitution. On the other hand, the Commission works on improving predictability, clarifying requirement and reducing burdens by simplifying in specific cases such as low volume and legacy spare parts, and making application dossier and fees fit for purpose.”
National Expert Dr. Jochem F. M. van der Waals from the Ministry of Infrastructure and Environment shared the Netherland’s experience on Risk Management for chemicals. He stated: “The RMOA aims at finding a policy option which is effective, proportionate, practicable and regulatory consistent to improve protection of health and the environment. Availability of exposure data at an early stage is key in making the right choice.”
During the workshop, ECHA’s Scientific Officer Denis Mottet shared knowledge gained from past experiences with authorisation applications. In addition, industry experts were represented by Christian Schmitt, REACH Substance Coordinator Performance Chemicals Division of BASF, who presented Risk Management Option Analysis of the UV absorber. Examples of ADCA substance were presented by Sabine Dröge, Legal Assessor and Deputy Managing Director of PolyComply Hoechst, addressed different Risk Management Options for substances used exclusively in industrial settings and already subject to workplace legislation.
Last but not least Michel Baumgartner, Secretary General of EUROPUR and EURO-MOULDERS, together with Ronal Van den Bosch, PU, EHS, Sustainability & Compliance of Dow Benelux, presented a new approach on REACH Restriction based on the example of diisocyanates.
Following the success of this first REACH Workshop, EuPC will be organizing a follow-up event in the fourth quarter of 2016.