REACH

REACH, the current EU legislation for the Registration, Evaluation and Authorisation of Chemicals (Regulation (EC) No. 1907/2006) came into effect on June 1st 2007.

The most important objectives of REACH are the improved protection of human health and the environment from the risks associated with chemical substances. At the same time, the intention is to strengthen the competitiveness with the EU.

There is a general duty to register all chemical substances, which are put on the EU market, according to the principle: NO DATA - NO MARKET:

Manufacturers and importers of existing chemicals, which have already been on the market, can benefit from transitional periods for final registration up to 11 years by pre-registration of the substances. The pre-registration period of 6 months ended December 1, 2008.

Without registration new substances may not been manufactured or imported into the EU in quantities exceeding 1 tonne/year.

This applies to substances on their own, but also in preparations and - certain cases - also in articles.

Substances of Very High Concern (SVHC) are subject to authorization, because the hazards of SVHC on human life and the environment can be serious and are sometimes irreversible.

The authorisation will only be granted if the applicant is able to provide proof that the risks can be sufficiently controlled during the use of the substance.

  • These substances include, among others:
  • Substances meeting the criteria for classification as carcinogenic, mutagenic or toxic for reproduction (CMR) category 1 or 2;
  • Substances which are persistent, bio accumulative and toxic in accordance with the criteria set out in Annex XIII of the REACH regulation (PBT and vPvB-Substances);
  • Substances having endocrine disrupting properties.

FUCHS Objectives

FUCHS is committed to proactively protecting and conserving the environment and providing a safe and healthy work place
Therefore Fuchs fully supports these objectives and is actively engaged in implementing the regulations.

REACH shall not have any negative impact on our products to ensure they will continue to be available under REACH without any REACH-induced changes in product characteristics or quality.

FUCHS will maintain timely, intensive, open and fair communication with all up-stream and down-stream partners in the supply chain, to ensure we will fully meet our legal obligations on time.

Current Status of implementation:

In close cooperation with our suppliers we have made sure that all substances in our products have been pre-registered on time. This also applies to imported FUCHS products. FUCHS Europe Schmierstoffe has been appointed as so-called "Only Representative" to fulfil all REACH obligations for imported FUCHS products.

Thus we have reached the first milestone in the implementation of REACH: Our products will continue to be available under REACH without any REACH induced changes in product characteristics or quality. So what are the next steps?

Uses of FUCHS products

After the expiry of the pre-registration period on December 1, 2008, manufacturers and importers of chemical substances need to collect all necessary information for their registration dossiers.

The registration of a substance also includes all uses during the complete life cycle and the associated exposure scenarios as well as the recommended operational conditions and the risk management measures for a safe use.

After registration the substance may only be used in identified and registered uses. If a downstream user recognizes that his use is not covered by the registration he can either notify the manufacturer or importer of this use asking him to include this use in their registration or register the use himself. In any case this will cause additional costs and efforts.

Therefore we would like to gather all information on uses in our supply chain and ensure they will be covered in the registration.

The so-called "Use Descriptor System" has been developed In order to standardize and simplify the communication in the supply chain. The Use Descriptor System consists of 5 main elements:

  • Sectors of Use -SU
  • Product Categories - PC
  • Article Categories - AC, 
  • Process Categories - PROC
  • Environmental Release Categories - ERC

You can find a comprehensive overview of the various use descriptors in English and German (Translation according to BDI Standard Phrase Table) following this link: Use Descriptor System.pdf

In order to minimize the efforts for our customers we have mapped typical uses of FUCHS products according to the use descriptor model. Please click on the following link to find the list of FUCHS products and their typical uses. (FUCHS Product usage allocation.xls)

In the left column you can find the product names or product groups. Please click on the little arrow in the first row of the column to get a selection list of all products. Under "user defined" you can also search by product name or part of a product name.

If your use is not covered or not covered adequately, please contact us as soon as possible.

If we do not get any feedback from your side, we will assume your use has been adequately described.

You need further information?

We are also happy to answer your questions directly. Please do not hesitate to contact us:

Fuchs Lubricants (UK) plc
Mr. Steven Pritchard
REACH Downstream Manager
Tel: +441782203877
Email: product.safety@fuchs-oil.com