REACH has been in force in the European Union since 2007 and has pioneered a new approach to improve chemical safety for workers, for the general public and for the environment. A key part of its concept is the registration of all existing substances on the market (with the exception of clearly defined exemptions) and it no longer limits registration requirements only to newly introduced substances. All substances imported into the EU above 1 tonne per annum require REACH registration (unless they meet the exemption requirements outlined in Annex IV and V of the legislation). In order to allow industry time to comply with these new requirements REACH sets transitional measures. Until December 1, 2008 companies were able to pre-register their previously imported/manufactured substances under REACH. Substances being imported/manufactured for the first time can be still pre-registered today as long as they can be considered as phase-in substances and their registration deadline has not already passed. Pre-registration allows companies up to 10 years to complete the full registration process while continuing to market their products. The timing of the full registrations depends on the volumes and, in some cases, the hazards of the chemical substances. At this moment, all substances imported or manufactured above 100 tonnes per annum must already have been registered by the relevant manufacturer or importer. Also all substances classified as CMR (Carcinogenic, mutagenic, reprotoxic) imported above 1 t/y had to be registered. All remaining substances imported or manufactured above 1 tonne per annum need to be registered by June 2018.
REACH Status at Air Products
At Air Products, we have been preparing for the REACH legislation since its publication in 2006. Air Products’ REACH compliance project is appropriately addressing all requirements of the legislation at its various stages.
We can confirm that Air Products has successfully pre-registered all substances in our products as planned and we have worked with our suppliers to secure our raw material positions.
In addition, we ensured all relevant substances have been registered in the appropriate supply chains before the 2010 and 2013 deadlines. However, please be aware that many substances are still to be registered before the 2018 deadline, which may explain why some information (e.g. registration numbers) will not yet be available for a number of products’ components.
Products Covered by the REACH Compliance Project
Through the link below you can access the list of products that are covered by our pre-registrations, registrations or exemptions.
Important notice for non-EU based customers
The Air Products REACH compliance programme allows Air Products legal entities to import the products listed below to EU countries or manufacture it in EU. When purchasing these products, EU customers are then considered downstream users and do not need to pre-register or register. The Air Products compliance programme does not cover imports of these products legal entities other than Air Products, for example importing these materials by non-EU based Air Products customers. If you are in this situation, please contact us to review your specific situation.
Industrial and Specialty Gases
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If you cannot find your product or have a question about REACH, please contact our Quality Europe team or send an inquiry to our REACH Team. Additional information is also available through our REACH Frequently Asked Questions (FAQ).
We plan to complete the registration of all our products from the lists above in accordance with the schedule provided by the legislation. There is a possibility that despite our efforts, supply conditions could change between now and the 2018 registration deadline, resulting in some products not being registered as currently planned. Please be assured that, in such an event, we will try to provide a warning as early as possible in order to manage an orderly transition to an alternative Air Products product.
Information for non-EU based Customers
As global supplier, Air Products is offering some products on a global basis. Our customers may purchase these materials outside of the EU and subsequently import these as is or as part of a formulation into the EU. An importer of these materials into the EU must follow all REACH requirements defined in the regulation for all substances contained within the product. The fact that product may be included in the list of products planned to be covered by Air Products‘ REACH Compliance Project does not automatically free other importers from REACH obligations (mainly pre-registration and registration) e.g. we may have registered all the substances, but not necessarily the non-EU supply chains in question.
However there are mechanisms defined in the legislation which can allow us to cover imports of our customers through nomination of an Only Representative. If you are interested in possible coverage of pre-registered or registered products by an Air Products nominated Only Representative please send your inquiry to our REACH Team. We will evaluate your inquiry and inform you if the coverage is possible.
Air Products can confirm that it has duly obtained pre-registration numbers for all pre-registered substances and that all products listed above are covered by pre-registration, registration or exemption under the REACH directive for each necessary supply chain.
The pre-registration number is randomly generated and does not have the structure or meaning of a registration number; it is not substance or company specific. Therefore the recommendation of both the EU Commission and CEFIC is that this number does not have to be published. Accordingly, Air Products’ policy is not to provide pre-registration numbers.
We understand that our customers, who are not necessarily members of the relevant SIEFs, may wish to have the pre-registration numbers in order to get additional assurance. However, we trust that our clear, unequivocal statement of confirmation of pre-registration contained herein is adequate assurance.
Registration numbers will be disclosed in the Safety Data Sheets in accordance with relevant requirements.
Substances of Very High Concern (SVHCs)
SVHC substances include CMR’s (Carcinogen, Mutagen, and Reproductive Toxins), PBT’s (Persistent, Bioaccumulative and Toxic), vPvB’s (very Persistent and very Bioaccumulative) or substances representing equivalent concern (e.g. endocrine disruptors and respiratory sensitisers). These substances can potentially be included in Annex XIV and be subject to authorization in the future. ECHA is continuously working on updates of the candidate list of substances for inclusion into Annex XIV and on the publication and updates of the Annex XIV itself.
Air Products continues to track updates to the Annex XIV list and proactively communicates to those customers purchasing products containing these substances in line with its obligations under REACH regarding the inclusion of such substances in any of Air Products’ products.
Air Products will keep such customers updated on our future plans for any products which will become subject to Authorization. We will also support customers in the process of transition to alternative products if necessary.
View more information on downstream uses
Please be aware that substances exempted from the obligation to be registered by Annex IV and V will be available for any use unless limited by other regulation. These substances will not require communication of identified uses to the supplier because it will not be necessary to develop exposure scenarios for them. Most of the common air gases supplied by Air Products are exempted by inclusion in Annex IV or V—see “Industrial and Specialty Gases” link above under section “Products covered by REACH compliance project”.
Safety Data Sheets and REACH
Where registrations have been finalized we are in a position to update our SDSs (Safety Data Sheets) as required with a registration number and new information on safe use. If you do not see this information in one of the SDSs it means that we are still working on the update or the product has not yet been registered or is exempted from the obligation to be registered.
Classification, Labelling and Packaging (CLP) Regulation and REACH
The new European Classification, Labelling and Packaging Regulation, referred to as CLP (Regulation No. 1272/2008) is closely related to REACH. We can also confirm that we continue to work to maintain compliance with this regulation. We have implemented the following changes corresponding to the different requirements according to deadlines in the registration:
- We have classified all pure substances in our products according to CLP criteria
- These classifications have been notified either by Air Products or our suppliers to ECHA
- All products are properly labelled according to CLP regulation including both pure substances and mixtures (please be aware the some packaging with old labelling may still be in the supply chain, but all products leaving our production sites are now CLP labelled).
- SDSs are updated to show classification and labelling information according to the new CLP requirements.
For more information about the REACH legislation and related guidance documents, please visit the ECHA website.