We are pleased to confirm that Lubrizol products supplied to you from a Lubrizol plant in the EU conform to REACH; moreover, we can confirm that all relevant substances were pre-registered by Lubrizol and/or the EU supplier.
If you receive any products direct from a non-EU Lubrizol plant and have entered into an Only Representative agreement with an in-force DRC with Lubrizol, then we can confirm that all relevant substances are in compliance with REACH requirements, should you receive the products in the EU or export the products to the EU. If you export Lubrizol products to the EU, either as part of your product or in their neat form, and have not previously discussed an Only Representative service with Lubrizol, please inform your account manager so that the REACH status of these products can also be confirmed.
REACH Registration on Schedule
Lubrizol has completed all 2010 registrations and still intends to register all the other substances that we pre-registered.
Registration is an Ongoing Process
The registration of all substances Lubrizol manufactures and/or imports is an ongoing process that will necessarily take several years to complete. This is because registration deadlines are determined by tonnage volume (and hazard in some cases). Additionally, some Lubrizol products also contain purchased components, and our suppliers may have earlier or later registration deadlines than Lubrizol. However, during the registration period, these substances—and products sourced from a Lubrizol EU facility and products sourced from a non-EU facility and covered by our Only Representative service, containing these substances—remain in conformity with REACH.
The following registration deadlines now apply for phase-in (pre-registered) substances:
1st June 2013 for substances manufactured or imported at 100 tonnes/annum or more
1st June 2018 for substances manufactured or imported at 1 tonne/annum or more
The registration number will be communicated through the supply chain by the Safety Data Sheet (SDS) or the documentation provided by the supplier to enable appropriate risk management measures to be identified when a SDS is not required. No additional communication of the registration number is legally required. The availability of the registration number is not considered as a major change and will therefore not necessarily trigger an immediate update of the SDS. For mixtures, a registration number may not be available for all hazardous ingredients shown on the SDS because the multiple substances used in the mixture may have later registration dates.
As most Lubrizol products are complex mixtures comprising substances with different registration deadlines, it currently is not possible to provide a definitive registration date per product because, for most products, some components will have an earlier registration deadline than others. We can, however, confirm that there are currently no plans to reformulate or discontinue any products as a result of any REACH requirements and, furthermore, we do not anticipate this situation changing in the foreseeable future. If there are changes in our supply plans as a result of REACH, you have our assurance that we will inform you at the earliest possible opportunity and work with you to minimize the impact of our decision.