The new European Chemicals Regulation (REACH) came into effect on June 1, 2007. It imposes new obligations on all manufacturers and downstream users of chemicals. DyStar started to address the implications of REACH very early on.

Interview with Dr. Eva Leweke

Dr. Eva Leweke is Manager in DyStar’s Product Safety, Ecology Group. She studied biology at RWTH Aachen, Germany, and Michigan State University, USA, specializing ecotoxicology

DyStar is well-prepared for REACH

We will be pre-registering all substances produced in Europe and imported into Europe for which registration is required within the deadlines set

We will be contacting you to obtain the relevant information in good time but it is currently too early for this

Safety data sheets issued by DyStar since June 1, 2007 comply with the new requirements; safety data sheets issued up to May 31, 2007 used the old format and will remain valid until they are updated

What are the goals of REACH?

One goal of the new Regulation is to improve knowledge of chemical substances (hazard, exposure, risk) and thereby enhance the protection of human health and the environment, while strengthen the innovative capability of the EU chemicals industry. Another goal is to give greater responsibility from authorities to industry to manage risks and to provide safety information that will be passed down the supply chain.

Dr. Eva Leweke is Manager in DyStar’s Product Safety, Ecology Group. She studied biology at RWTH Aachen, Germany, and Michigan State University, USA, specializing ecotoxicology

What are the implications of REACH for the apparel industry in the EU?

Apparel manufacturers within the European Community will be affected to a huge extent because from now on they are legally obligated to use only substances pre-registered / registered according to REACH. For retailers and brands it is easier as mainly Article 7 (substances in articles) of the Regulation is of interest. Meaning only substances in articles intended to be released and used in quantities greater one tonne per year have to be registered.

Do wellness finishes fall under this exception?

REACH has come to the conclusion that in the case of wellness finishing containing a microencapsulated coating of cosmetic ingredients that are released to interact with the skin the fabric contains a preparation that is released onto the skin but does not constitute the “release of a substance out of an article” as defined by Article 7.

What about finished products manufactured outside the EU?

Import of garments into Europe is nearly beyond the scope of REACH (except for Article 7) as REACH is mainly focused on substances.

REACH establishes extensive risk management for the entire life cycle of chemicals, covering all stages in the process chain. What does that mean?

The aim is to ensure safe handling of chemicals throughout their whole life cycle. This is only possible if manufacturers and downstream users work together closely. Users are required to provide extensive information for their suppliers and customers. For example, suppliers must be notified of all uses of the chemicals purchased as they are required to take these intended uses into account in their chemical safety report. Based on this evaluation, the revised and extended safety data sheet must contain details of how to ensure safe handling of the substance or preparation. For this communication the extended SDS will be the main instrument in the supply chain.

What other information is mandatory?

Downstream users are required to notify suppliers of any new findings relating to a chemical. This information is conveyed through the supply chain to the manufacturer, who incorporates it in the safety evaluation of the chemical. In this way, REACH fosters communication between all stages in the supply chain, which I think is very positive. DyStar already meets almost all of the requirements on this level. New is that both sides are required to maintain reliable documentation. That entails a good deal of bureaucracy and naturally costs. The basic aim is for manufacturers to record all data centrally so they can be used in risk evaluation.

What action has DyStar taken to prepare for the new requirements?

We actively monitored and assessed developments already long before the Regulation was adopted. We also worked on various projects at industry associations and a project organized by the German Environment Ministry to provide assistance in the establishment of effective risk management structures along the textile supply chain. It focused primary on future collaboration/communication between manufactures and downstream users within the focus of REACH. In addition, we are collaborating with the NordWest and TEGEWA textile associations on REACH Implementation Project 3.2. developing standard exposure scenarios for the textile industry as a tool for effective communication within the textile supply chain.

What is DyStar’s view on the new European chemicals legislation?

Fundamentally, we welcome the fact that it enhances clarity about the properties of chemicals manufactured in the EU and chemical imported, so we can better assess and understand their impact on people and the environment. Unfortunately, it also entails a lot of bureaucracy. However, REACH also introduces a number of simplifications and opens up new opportunities for the European chemical industry. It will help the chemical industry to gain trust and prove that it handles its products and raw materials safely and responsibly. I believe that if REACH is implemented efficiently and intelligently, it could give us a competitive advantage. That evidently depends on the strategy adopted. DyStar has realized that and taken action accordingly.