Ceepackaging

Environment

Reaching out

As an EU Regulation, REACH (Registration, Evaluation,
Authorisation and restriction of CHemicals) directly
imposes its obligations on companies from 1 June 2007
without the necessity of implementing national laws.
Although the focus of REACH is on substances,
the legislation deals also with substances in articles and
in preparations. EUROPEN understands that packaging
falls under the definition of an article in the Regulation
which states “article: means an object which during
production is given a special shape, surface or design
which determines its function to a greater degree
than does its chemical composition.”
Pulp and paper, plastics, metals, glass, coatings,
printing inks and adhesives are among materials used
in packaging that are affected by REACH. Packaging
material suppliers, converters and importers of raw
materials and finished goods should ensure that they
are aware of their obligations under the provisions
dealing with substances in articles, of the need for
pre-registration and registration of substances and,
in some cases, authorisation of the substances.
In general, substances on their own, in preparations
(e.g. inks, coatings and adhesives) or in articles
(e.g. packaging) may only be manufactured, put
on the market and used in the applications for
which they are registered.
The deadlines for taking actions are very tight and
the most urgent step to consider is pre-registration.
Companies should begin to audit their product portfolios
now and initiate dialogue with customers and suppliers.
Packaging converters and packer-fillers/brand owners
should encourage suppliers to pre-register all
substances during the mandatory June to December
2008 timeframe. While there is no penalty for not
subsequently registering substances that have been
pre-registered, there is no guarantee that substances
that have not been pre-registered can be registered
according to the timeline laid down in the Regulation.
Unregistered substances will eventually have to be
taken off the market. Key decisions, on which substances
may or may not have to be withdrawn from the market,
can be postponed on condition that they have been
pre-registered.
Although in general the registration obligations fall
on manufacturers and importers, downstream users
need to ensure that their specific uses are registered.
This means that downstream users will have to tell their
suppliers how they use the substances in their products.
Because the REACH Regulation allows for joint
registration (the so-called “one substance one
registration” approach) the need and the benefit
of this supply chain information exchange is clear.
Clarity, collaboration and communication will be
essential to make REACH work.