EU REACH - CBIA · 19/06/2013 · Sales Offices Bangalore Beijing Seoul Shanghai Shenzhen Singapore Taipei Tokyo North America Europe Asia Excludes Joint Ventures 2012 Revenues by

What does it mean for US Manufacturers?

EU REACHAnita Jain

Global EH&S Director

Rogers Corporation

June 19, 2013

2

A global leader in materials

technologies that power, protect

and connect our world

Revenues: $499 M (2012)

Employees: 2400 worldwide

Headquarters: Rogers, CT, USA

Ownership: Public - ROG on NYSE

About Rogers

Global HeadquartersRogers, Connecticut

ManufacturingCarol Stream, Illinois

Chandler, Arizona

Rogers, Connecticut

Woodstock, Connecticut

ManufacturingEschenbach, Germany

Gent & Evergem, Belgium

ManufacturingSuzhou, China

Ansan, Korea

Nagoya, Japan (JV)

Sales OfficesBangalore

Beijing

Seoul

Shanghai

Shenzhen

Singapore

Taipei

Tokyo

North America

Europe

Asia

Excludes Joint Ventures

2012 Revenues by Region*

Our Global Reach

3

>75% of Sales Outside US

Our Core Businesses

4

Power Electronics Solutions

High Performance Foams

Printed Circuit Materials

Powering Protecting Connecting

DBC Substrates,

Laminated Busbars, and

Integrated Components

Proprietary Cushioning,

Sealing and Impact

Protection

High-Frequency Circuit

Materials

Supply Chain Routes

5Rogers Confidential


REACH At-A-Glance

• Registration

• Substance of Very High Concern

• Downstream User Obligations

• Q & A


• Registration, Evaluation, Authorization of Chemicals –REACH

• EU Directive – EC 1907/2006

• Entered into force on June 1, 2007

• Central Administration: European Chemical Agency (ECHA), Helsinki

• Consolidated the EU chemical laws into one legislation

• Shifting chemical safety responsibilities from government to industry - “Duty of Care”

REACH

Why REACH

• To ensure protection of human health & the environment.

• To ensure sufficient toxicological data is present for high volume chemicals.

• To stimulate innovation and development of safer substitutes.

• To promote integrated, modernized, proactive and forward-looking approach to chemicals management.

• To “level the playing field” with companies importing substances into the EU.

REACH Scope

• Covers some 30,000 substances manufactured or

imported into any of the European Union countries in

quantities of 1 ton or more per year

• Exemptions:

– medicinal products, food additives

– polymers

– pesticides and biocides

– ores, fuels, cements

– chemicals in research labs

This presentation may not be reproduced, copied, published, transmitted or otherwise distributed for any reason.

REACH - Registration

• Applies to all substances that are manufactured, imported, used as intermediates or placed on the EU market in quantity >1 ton per year

– Substances: Chemical elements and compounds

– Preparations: A mixture or solution composed of two or more substances

– Articles: An object which during production is given a specific shape, surface or design which determines its function to a greater degree than does its chemical composition.

– Substances in articles which will be released intentionally.

10

REACH Scope

REACH applies to:

– Importers: Responsible for import

– Manufacturers: Responsible for manufacturing

– Distributers: Places on the market

– Producers: Makes or assembles an article

– Downstream Users: Uses the substance



• Requires pre-registration and registration of

substances >1 ton/year

- Pre-registration completed in Dec. 2008 with >2 million

pre-registrations

– By Nov. 2010: >1000 tons, CMR >1 ton

– By May 2013: 100 – 1000 tons

– By May 2018: 1 – 100 tons

12


• Only EU companies can complete registration.

• Non-EU companies must appoint “Only Representative”

• One Substance Information Exchange Forum (SIEF) for

each substance with the same identity.

• Late pre-registration is not an option.

• Companies must submit full registration dossier prior to

importing into EU.

REACH – Evaluation & Authorization

• Substances with serious effects on human health and

the environment – Carcinogens, Mutagens, PBTs

• ECHA publishes “The Candidate List” every six months

• The candidate list = SVHC – Substances of Very High

Concern

• Posted on ECHA website: http://echa.europa.eu/

• Currently there are 138 SVHCs on the Candidate List


REACH – Evaluation & Authorization

Candidate List Authorization List

Communication of Safe

Use (B2B & B2C)

Use of these

substances is

BANNED unless

Specifically

authorized!Notification to ECHA if >1 Ton

SUBSET

http://www.chemsec.org/what-we-do/sin-list

Substances in Articles

• There is no grace period between when a substance is

declared an SVHC and when companies must declare its

presence in the article.

• Products that contain SVHC >0.1% w/w are subject to

additional obligations such as notification to ECHA and

communication of safe use.

– B2B Sale: At the time of sale

– B2C Sale: With in 45 days of the request

Impact on US Manufacturers


• EU customers may require US manufactures to provide

Product Declarations.

• US Manufactures may not be able to sell products that

contain substances that are listed on the authorization

list.



Substances intended to be

released > 1 TPY

Does the article contain listed

SVHC?

Is the concentration of SVHC

>0.1% w/w

Does the total volume of

SVHC exceed I TPY?

Registration obligations

Communication of safe

use

Notification required

Downstream Users (DU)

• Ensure your supplier has or is planning to register all

substances.

• Must receive e-SDS where applicable.

• Must follow “intended use” instructions provided in the

e-SDS.

• Suppliers of articles: Provide safe use information when

SVHC > 0.1% (w/w).

REACH – Registration

What Should Non-EU Manufacturers Do?

• Develop a good understanding of the REACH

regulations and guidelines and its applicability to your

company.

• Build a multidisciplinary team to address REACH

obligations (R&D, Supply Chain etc.).

• Provide training to all relevant parties to raise

awareness.

• Develop an inventory of everything exported to EU (raw

materials, finished goods, packaging materials etc.)

REACH – Registration

What Should Non-EU Manufacturers Do?

• Collect and analyze data to determine tonnage bands and any data gaps.

• Develop REACH compliance strategy:

– Consider engaging an “Only Representative” to complete the registration process OR

– Rely on the upstream manufacturer’s registration OR

– Sourcing the material locally etc.

– How to address SVHCs?

• How to respond to customer inquiries?

Other EU Requirements

• RoHS: Restriction of Hazardous Substances (EEE)

• CLP: Classification, Labelling & Packaging - GHS

• WEEE: Waste Electrical & Electronic Equipment

• IMDS: International Material Data System

• GADSL: Global Automotive Declarable Substance List

• ELV: End-of-Life Vehicles

• EUP: Energy Using Products

• Battery Directive

REACH & Asia

Many Asian countries have adopted REACH & RoHS type of regulations.

CHINA: China Order No. 7 – Administration of New Chemical Substances in China

IECSC – Inventory of Existing Chemical Substances Produced or Imported in China

KOREA: Recently adopted REACH type legislation.


Rogers Corporation

Environment, Health, and Safety

Internet Site

24


Environment, Health, and Safety

Internet Site

REACH SVHC Letters

25

This presentation may not be reproduced, copied, published, transmitted or otherwise distributed for any reason.26

Rogers’ Strategy

• A sustainable approach is needed:

– To maintain global market access.

– At lowest cost.

– To minimize business disruptions.

– To minimize legal liabilities.

– On-time product development.

“Capture as a Business Opportunity

instead of Liability”


Questions

27

Documents

EU REACH - CBIA · 19/06/2013 · Sales Offices Bangalore Beijing Seoul Shanghai Shenzhen Singapore Taipei Tokyo North America Europe Asia Excludes Joint Ventures 2012 Revenues by