The EU REACH Regulation EC No. 1907/2006 requires that uses of a substance be identified and the risks associated with the identified uses to be controlled. In addition, some substances are required to be reviewed with a chemical safety assessment; while hazardous substances require the creation of exposure scenarios that are communicated up and down the supply chain.
Lubrizol's products typically fall into one of three categories.
1. The product is a mixture of purchased raw materials and/or substances manufactured by Lubrizol.
An eSDS is not required for preparations under the REACH regulation. As a result, end uses and instructions on safe use are communicated through the SDS.
2. The product is a single substance supplied by Lubrizol.
In this case, Lubrizol intends to register uses for this substance consistent with the marketed end use. When the substance is a purchased material, Lubrizol is working to communicate end uses consistent with the marketed end use to the supplier and confirming that the intended uses have been or will be covered in the registration dossiers. Until this work has been completed, which may be after the 2018 registration deadline, Lubrizol cannot confirm the registration status of any uses of substances not registered by Lubrizol.
3. The product is a polymer or a blend of polymers manufactured by Lubrizol:
The registration of polymers is not required by the REACH regulation, but it does require the registration of the monomers. For polymers or blends of polymers, Lubrizol intends to register the monomers used to produce these polymers or use monomers which have been registered as required by the REACH regulation. The REACH regulation does not require the identification of uses for polymers in the dossiers of the relevant monomers.
Downstream users have the right to communicate their uses through the supply chain for consideration and possible inclusion in the Chemical Safety Report. If your intended use of products purchased from Lubrizol is different than the marketed end uses, you may communicate this anticipated use in accordance with Article 37(2) of REACH. If you need to communicate a new specific product use of a Lubrizol product, please contact us at: OnlyRepresentative@Lubrizol.com.
If a new use is identified for a certain Lubrizol product, we will assess if this use is already covered by the exposure scenario already included in the registration dossiers. If the new use is not covered, and if this new use is supported by Lubrizol, we intend to add this use in the appropriate registration dossier(s). Accordingly, Lubrizol will work with the appropriate raw material suppliers to add the new intended use to their registration dossier(s) as well. We will endeavor to update the dossiers within a reasonable timeframe. Due to the complexity of the REACH registration process, there will likely be an unavoidable delay between acceptance of a new product use communicated to Lubrizol and the inclusion of a new intended use in the applicable substance registration dossiers.
This document is provided for information purposes only and does not constitute legal advice. While every effort has been made to ensure the accuracy of the information contained herein, The Lubrizol Corporation cannot be held liable for any errors in or any reliance upon this information.
