2006 ANNUAL SCIENTIFIC MEETING
REACH-ONE C0MPAN.V1S VIEW
Do-Lung Pan and Julie Gari
Dow Corning
95
Personal care companies and their ingredient suppliers will need to work quickly
to understand the implications of REACH and how to adequately respond to it in
both the short and longer term ..
Like many others who are engaged in the manufacture, distribution and use of
chemicals, Dow Corning has been actively tracking and contributing to the
ongoing review of chemicals policy and management around the world. Within
the European Union (EU), the draft REACH 1 regulation is being widely debated
and communicated in the media and, as a result, is generating enquiries by and
of chemical suppliers.
Dow earning's corporate values shares the aims of the draft REACH regulation
in improving levels of protection to human health and the environment.
Dow Corning will provide insight into how it is preparing for REACH including
organization structure, communications awareness training, management plan
and identifying opportunities and threats. Dow Corning will also describe how
they plan to work with customers throughout the various milestones within the
REACH effort.
• Communications up and down the supply chain
• Sharing information while protecting intellectual property
• Working within global multi-functional teams
• Investment into sound scientific data
• Managing the issue through science, communications &advocacy
REACH legislation will be enacted. Proper planning and preparation will not only
allow chemical manufacturers and their customers to survive, but you can thrive.
1 REACH -Registration, Evaluation &Authorization of Chemicals

96 JOURNAL OF COSMETIC SCIENCE
REACH ...ONE COMPANV1S I/JEW AND RESPONSE
TO THIS IMPORTANT INDUSTRY CHALLENGE
Peter Megaw
Croda International Pie.
REACH is corning. It is corning fast, and when it arrives it will be here to stay with us for a long time.
As I write this pre-print the latest available official text of the legislation is the "Common position adopted
by the Council with a view to the adoption of
a Regulation of the European Parliament and of the Council concerning
the Registration, Evaluation, Authorization and Restriction of Chemicals
(REACH) ........."of June 2006. However it is expected that this text already indicates the major
elements of what will within a few months be adopted as European Union Legislation.
It is already evident that the legislation represents a revolution in chemicals control in Europe, and one
whose requirements the legislation itself foresees will have to be implemented largely by chemicals
manufacturers, suppliers and down-stream users, rather than by the regulatory authorities themselves.
I am not going to try to review the whole of the legislation here. Instead I am going to consider how
companies should be preparing by reference to specific selected elements of the legislation. What they will
need to do, what they can do in advance, what it is unreasonable to expect can be done now, what we will
be expected to have done already. I am going to consider some of the issues that are of special interest to
cosmetic ingredient suppliers and cosmetic ingredient users. I will give examples of actions that Croda, as a
company supplying significant quantities of ingredients for cosmetics and personal care, has taken and is
taking.
Pre-registration.
The article on "entry into force and application" (the last Article -140 -in the text of June 06) indicates
that the Regulation in general will come into force 20 days after publication in its final form and Title II
(Registration of substances) will come into force 12 months later. If we do nothing in advance, this means
that we would need a full notification dossier for all substances we put on the European market 12 months
after corning into force (this could be as early as spring 2008 therefore!). To avoid this, and take advantage
of appropriate 3, 6 or 11 year "extensions" of time allowed for "phase-in" substances (i.e. those already in
the European Inventory of Existing Chemical Substances [EINECS] or of similar status) companies must
pre-register their interest in a substance.
Who needs to pre-register?
Essentially anyone manufacturing a substance in Europe or importing the substance into the European
market needs to pre-register. This includes importers of materials as components of preparations. Note that
in this context most cosmetics are "preparations" as defined in the REACH regulation and not "articles".
What is needed to pre-register?
The requirements are given in Article 28 of the June 2006 text.
These include:
(a) the name of the substance as specified in section 2 of Annex VI, including its EINECS and CAS
number or, if not available, any other identity codes ,..
(b) his name and address and the name of the contact person and, where appropriate, the name and
address of the person representing him ...
(c) ...the envisaged deadline for the registration/tonnage band
...2. The information referred to in paragraph 1 shall be submitted within a time period starting on [...12
months after entry into force] and ending on[... 18 months after entry into force ...]*.