REACH and its effects upon Regulations for Brazing Fillersand Fluxes

What is REACH all about?

REACH stands for Registration, Evaluation, Authorisation of Chemicals. This is a European Union regulation on chemical substances, which is designed to centralize and simplify legislature on chemicals throughout Europe. REACH came into effect on June 1st, 2007.

The REACH system is based upon the principle of autonomous responsibility. In keeping with the motto "No data, no market", REACH provides that chemical substances will need adequate data substantiation on physical characteristics, toxicality, environmental impact etc. in order to put them into the market place. In practical terms, this means that manufacturers and/or importers are themselves responsible for the safe handling of their chemical substances. They will be required to collect all data needed for assessment and to pass it along the supply chain.

REACH applies to all chemical substances manufactured or imported into the European Union in quantities of one ton or more per year. These must be registered with the new European Chemicals Agency (ECHA) in Helsinki. The principle rule is that the larger the quantity of chemical substance put to the market, the larger the number of substance characteristics there are to be determined.

Pre-registration

In 2008, all relevant substances had to be pre-registered with ECHA. The objective of such pre-registration was and is to provide manufacturers and importers of identical substances an opportunity to find each other in order to exchange relevant information. This is done in a so-called Substance Information Exchange Forum (SIEF), which is available for each single substance with more than one potential registrant.

Registration

Registration deadlines depend upon the quantities per manufacturer/importer  – and of course also the hazardous nature of the substance at issue. Registration in 2010 also of >100 t/a with R50/53 and >1 t/a with CMR 1 and 2. The first deadline for large-quantity substances from 1000 t/a will expire on December 1st, 2010. Such registration must include both a technical dossier as well as particulars on the safe handling of the substance at issue. From an annual production quantity of 10 t/a, manufacturers and importers must provide additional information in a chemical safety report on a substance's effects and environmental impact. A risk assessment on the basis of the intended use will also have to be provided for substances considered to be hazardous. Suppliers will be required to prepare an assessment of all risks inherent to a substance for all identified applications stated by their customers. The stated applications and/or a list of the identified applications will then be a component part of the safety data sheet.

Downstream users

Downstream users are defined as any natural or legal person established within the Community who uses a substance, either on its own or in a preparation, in the course of his industrial or professional activities. A manufacturer or importer, distributor or consumer is not a downstream user, other than a re-importer.

Downstream users have the opportunity to make information available in order to support the preparation of a registration. They have the right to inform their suppliers of their intended applications, which are then considered to be identified applications in the registration dossier and may be, but need not be, adopted to the safety data sheet as exposition scenario.

Safety data sheet

Since June 1st, 2007, the REACH directive has been regulating the structure and communication of safety data sheets. The prior requirements from the Safety Data Sheet Directive 91/155/EEC were to a large extent adopted and amended by a few new covenants (see box). Since that date, safety data sheets must be prepared in compliance with the REACH directive.

A safety data sheet must be made available without further request to buyers of substances or preparationsthereof in the event of

  •  hazardous materials and compounds,
  •  persistent, bioaccumulative and toxic substances (PBT),
  •  very persistent and very bioaccumulative substances (vPvB),
  •  substances itemized in the REACH candidate list.

The safety data sheet will be supplied to the customer no later than the first shipment of the material at issue. It must be made in the official language of the member state in which the customer of the substance/preparation has his registered office and in which the substance/preparation is put to the market.

REACH - Effects upon Brazing Fillers

Almost 100% of all brazing fillers are alloys composed of at least two elements (substances). As their function is predominantly defined by their chemical composition rather than by their shape, surface or design, they are considered to be preparations. Exceptions from this principle are brazing fillers consisting 100% of a single element (e.g. Cu 110).

In context with registrations, manufacturers of brazing fillers were notified about the application of elements by the competent syndicates, e.g. the European Precious Metals Federation for Silver

As long as there are no new findings in the respective SIEFs on classifications, REACH is not anticipated to have any direct effects upon brazing fillers.

REACH - Effects upon Fluxes

The state of facts for substances used for the production of fluxes is almost analogous to the situation for brazing fillers.

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