Lubrizol REACH Update

Brexit Impact on REACH

On June 23, 2016 the UK voted to leave the European Union. In accordance with Article 50 of the EU Treaty, UK and EU representatives will participate in a significant negotiating period, which is anticipated to take at least 2 years.  Lubrizol will monitor these negotiations and we look forward to understanding more as the details emerge.
 
In the meantime, Lubrizol's current REACH compliance processes will continue to operate as they have in the past.  Our Lubrizol Limited legal entity will continue to serve as the Only Representative for all non-EU legal entity's utilizing Lubrizol's REACH services.  Lubrizol Limited remains absolutely committed to assisting our customers as their OR under REACH.  Lubrizol will ensure that we are in a position to continue to support customers as OR once the next steps of the withdrawal process and UK-EU trade agreements are clear.
 
If you should have any questions, please feel free to contact REACH_Questions@Lubrizol.com.

 

REACH Registration on Schedule

Lubrizol has completed all required 2010 and 2013 registrations and still intends to register all the other substances that we pre-registered.

We are pleased to confirm that all Lubrizol products supplied to you from a Lubrizol plant in the EU conform to REACH. We also confirm that all relevant substances were pre-registered by Lubrizol and/or the EU supplier, and those substances are part of the REACH phase-in registration process.

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 (Declaration of REACH Conformance) with Lubrizol for those products, then we can confirm that all relevant substances are in compliance with the REACH requirements, whether you receive the products in the EU or export the products to the EU.

If you export Lubrizol products to the EU from outside the EU, either as part of your product or in their neat form, and have not established Only Representative service with Lubrizol for those products, please inform your account manager so that we can establish the necessary Only Representative service for you and your EU importer(s).

Registration is an Ongoing Process

The registration of all substances Lubrizol manufactures and/or imports is an ongoing process that won't be completed until May 31, 2018. 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 containing these substances - remain in conformity with REACH. This conformity applies to products sourced from a Lubrizol EU facility and products covered by our Only Representative service.

The following registration deadline now applies for phase-in (pre-registered) substances:

31st May 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 a 31st May 2018 registration date.

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.

For Additional Information

Send us an email if you would like additional information about REACH.

Or please contact your Lubrizol sales representative.