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British Rubber & Polyurethane Products Association


BRPPA Summer Newsletter: REACH

Posted on 26 July 2019


The modus operandi of UK REACH, if it needs to be enacted, continues to be of great concern. Through a statutory instrument the necessary legislation to set up the new regime has been enacted but Defra has already admitted it needs amendment. The biggest area of controversy is the huge cost likely to be borne by British industry (estimated to be over £1bn) in meeting the requirements of the UK authorities in providing the technical data underpinning UK registrations. These demands are being strongly challenged by the leading chemical industry associations with a good degree of support in Parliament.



• ECHA ramps up checks on existing REACH dossiers

The European Chemicals Agency (ECHA) is ramping up its checks on REACH dossiers. It plans to scrutinise all dossiers in the over-100 tonnes a year category by the end of 2023.
In April this year ECHA said it would be screening all registration dossiers in the 1-100 tonne category by 2027. These plans cover some 16,500 registered substances. ECHA has already announced that it would be increasing its compliance checks from 5% to 20% of dossiers. It will also examine enforcement measures in member states and their effectiveness in dealing with non-compliance.


• REACH Registrations

A year has passed since the final REACH registration deadline (when the threshold for registration was reduced to 1 tonne per year), but it would be “misleading to think that the registration phase is over”, according to the European chemical industry association, Cefic.
Read more By the day after the deadline of 31 May 2018 a total of 88,319 registrations had been logged by companies for 21,551 substances over the three tonnage-band, with a further 576 requests accepted under “exceptional circumstances” for an extension to submit the data. The agency has processed a further 6,968 registrations for 785 substances that came in after last year’s deadline. However, The European Chemicals Agency (ECHA) said it should be noted that these registrations are not all late submissions: “They could also be new market entrants who have to register before placing their chemical on the market.”
Meanwhile ECHA said it recognised early on that REACH registration could be burdensome for SMEs – mainly because of the cost of data and claim to have done their best in helping SMEs with simpler IT tools, DCG recommendations and solutions. The availability of laboratories to perform the tests was also quite challenging, but we were able to address this issue with the DCG solutions.” Reaching out to the smaller non-organised companies was “hard”, it added.
There appears not to be much evidence of specific chemicals disappearing off the market because companies would not be able to register them but it could be too early to say if there are still stocks available from before the last deadline, which can be still sold to fill supply gaps.



In 2017 the suppliers of MbOCA, a material used by some of our polyurethane elastomer members, was granted an authorisation for its use in the EU for four years. Although the authorisation has come into effect the formalities for the completion of the authorisation process have been repeatedly deferred, with the Commission yet to make a formal decision. In the meantime any application for an extension of the authorisation from the point at which the current authorisation lapses has to be submitted by October this year. The current supplier no longer wishes to supply and therefore will not be making this application. The consultants it used to make the existing authorisation are trying to put together a consortium of users to apply for this re-authorisation by the due date of October 2019. Our PU members are considering whether to join this consortium. The position is complicated by uncertainties over whether the applicable regulatory regime will be EU REACH or a separate UK regime following Brexit.



A study by PwC and Energy UK has revealed that 71 per cent of businesses now have an energy

strategy – up from 65% in 2017 – and 53% of strategies include energy efficiency targets. The

findings from a survey of 500 businesses of all sizes also included the observation that only a third

of industrial businesses expected to be fully reliant on the grid for all their supply within five years



BRPPA subscribes to the British Standards Institution and through this keeps abreast of standards both in the UK and in the international sphere. This is a very useful resource if you wish to be aware of standards affecting your products and also if you wish to join the BSI in the development of new standards or review of the old as committee members. You can do by completing an online application form and attaching/uploading your CV.

Information about being a committee member can be found online here. Please note, members need to state on their application that their organisation is part of BRPPA as well as state the names of the specific committees they want to join. Once BSI receives a member’s application its programme managers will contact them asking them for a nomination/recommendation from the Association.


American Chemical Society Rubber Division video

R.D. Abbott Company, Inc. and the Rubber Division of the American Chemical Society, ACS, have partnered together to produce a new video called, “Rubber: It’s Not Just Tires.” The video demonstrates the significance of rubber in everyday life and was designed to introduce the next generation of workers to this extraordinary industry. It can be found here or here.