Lubrizol REACH Update

Brexit Impact on REACH

On 29 March 2017 the United Kingdom triggered Article 50 of the Lisbon Treaty, expressing its intention to withdraw from the European Union within 2 years. UK and EU representatives have since been participating in a significant negotiating period, and announced a withdrawal agreement in late 2018, but the final details on what may happen after 29 March 2019 remain unclear.

Lubrizol is monitoring these negotiations as they relate to REACH, and working with the relevant industry associations and the UK Government to understand the next steps to minimise disruption to business and to ensure that the future UK chemicals management scheme is appropriate for the UK chemical industry.

In the meantime, Lubrizol's current REACH compliance processes will continue to operate as they have in the past.  We are working to move our Only Representative registrations for all non-EU legal entities utilizing Lubrizol's REACH services from Lubrizol Limited to a Lubrizol Belgian entity prior to 29 March 2019. We remain committed to assisting our customers as their OR under REACH and will continue to support our customers as OR through the next steps of the withdrawal process and beyond.  Additional information regarding the administrative OR change will be communicated during our annual OR renewal process.

If you should have any questions, please feel free to contact REACH_Questions@Lubrizol.com.

In case of no-deal, what steps is Lubrizol taking to mitigate impact on our customers?

For substances used by Lubrizol UK plants we have assessed the EU REACH impact for finished products shipped to customers in the EU27. As a result, we have identified additional registrations that we are completing to enable our Only Representative to support continued shipments to the EU27 after 29 March 2019. For substances used in our EU27 plants that are of UK origin we have identified additional registrations that we are completing for critical raw materials. For others we are in communications with our suppliers and actively reviewing our purchasing strategy and registration options.

Under the proposed UK REACH system we intend to grandfather all of our previous registrations within 60 days, and to notify all relevant substances within 180 days where we are currently either a UK Downstream user or where we ship within our EU27 manufactured products to our UK customers.

We do not at present envisage disruption to supply of Lubrizol products as a result of REACH and we continue to monitor this situation as plans for Brexit are developed by the EU and UK Parliaments.

If you should have any questions about particular products, please feel free to contact REACH_Questions@Lubrizol.com.

REACH Registration of Lubrizol Products

We are pleased to confirm that all Lubrizol products supplied to you from a Lubrizol plant in the EU or purchased from a Lubrizol EU legal entity conform to REACH. We also confirm that all relevant substances have been REACH registered by Lubrizol and/or its suppliers or are exempt from registration.

If you receive any products directly from a non-EU Lubrizol plant and have entered into an Only Representative agreement with DRC’s (Declarations of REACH Conformity), then 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 contact onlyrepresentative@lubrizol.com so that we can establish the necessary Only Representative service for you and your EU importer(s).

Communication of Registration Numbers

 Registration numbers 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 an SDS is not required. No additional communication of registration numbers is legally required. The availability of a registration number is not considered as a major change and will, therefore, not necessarily trigger an immediate update of the SDS.

We confirm that there are currently no plans to reformulate or discontinue any products because of REACH requirements. If there are changes in our supply plans as a result of REACH, 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.