On June 1 of 2007, a new regulation revolutionized the way in which chemicals are regulated in Europe. This regulation, known as Registration, Evaluation and Authorization of Chemicals (REACH), is the most comprehensive chemical regulation in the world to date. All manufactured and imported chemicals, whether by themselves or contained in mixtures or articles, are within the scope of REACH. Manufacturers, importers and downstream users are all responsible for compliance.

Objectives
With the implementation of REACH, the European Chemical Agency (ECHA) places the burden of ensuring the safety of chemicals and their supported uses squarely in the manufacturers’ court. By imposing a requirement that manufacturers and importers of a chemical share data and work together to compile a single data dossier, redundancies – in particular redundancy in animal testing - is avoided. By expanding the safety data sheets to include supported uses and the corresponding risk management measures, ECHA introduces the concept of “safe” or “supported” uses and other uses, which either have not yet been assessed or have been assessed and found to be unsafe. Lastly, with this new regulation ECHA creates an incentive for industry to innovate with directionally safer chemicals.

The Innovative Plastics "REACH Readiness" program is designed to ensure continued availability of finished goods (polymer preparations, film, and sheet) for our customers with operations in Europe. The program focuses on those finished goods that Innovative Plastics produces within the EU or imports into the EU as importer of record.

Substance pre-registration
On December 1, 2008, Innovative Plastics finalized its substance pre-registration program. Pre-registered substances represent both raw materials for the manufacture of polymers, and various purchased chemicals, which are subsequently used for the manufacture of polymer preparations (such as Lexan *, Noryl * or Valox * resin grade/color combinations), film, and sheet. Innovative Plastics will not communicate ECHA substance pre-registration numbers since this potentially could imply revealing business confidential details of our material technology.

In addition, Innovative Plastics completed its supplier evaluation program. This part of our "REACH Readiness" effort was set up to ensure that downstream users will have continued access to sourced raw materials for use within Europe.

Substances of Very High Concern
Through a press release on October 28, 2008, ECHA confirmed the identification of 15 Substances of Very High Concern (SVHC) that may become subject to authorization. Since then, and through the end of 2010, an additional 31 substances have been added to the SVHC list with more expected to be added annually by the European Union (EU). Innovative Plastics continually reviews its database of approved raw materials and identifies the use of any of these candidate substances as a raw material to produce finished goods within the EU or to produce finished goods which Innovative Plastics brings into the EU as importer of record. If we were to determine that an SVHC is used, all attempts would be made to eliminate the material and/or find a substitute. In the future, any relevant SVHC information will be conveyed through updated Safety Data Sheets.

Safety Data Sheets
Safety Data Sheets for Innovative Plastics finished goods have been adapted to meet REACH format standards and can be requested through productinquiries@sabic-ip.com.  

Registration
Innovative Plastics has successfully registered all required chemical substances in 2010 and received REACH registration numbers from ECHA. This will allow continued manufacture, use, and importation into the EU for these chemicals. Also, SABIC is actively preparing for future registration needs for upcoming registration deadlines where necessary. SABIC continues to participate in Substance Information Exchange Forums (SIEFs) and consortia as appropriate.

Customer Queries
The Innovative Plastics business receives a large number of REACH related customer requests. These customer requests all differ in format and include requests for declarations, compositional information, participation in customer programs, etc. It is not possible to manage and sign up to various “REACH Readiness” customer initiatives in parallel. Instead, Innovative Plastics decided to ensure “REACH Readiness” through one global, cross-functional program and to respond to customer queries through “REACH Readiness” program statements.

We are committed to continue providing regular “REACH Readiness” progress updates throughout the (pre-)SIEF and registration phases. Our customers, however, remain responsible for complying with their own specific obligations under REACH.