REACH
Registration, Evaluation, Authorization and Restriction of Chemicals

The Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation impacts all organizations within the chemical industry, including manufacturers, importers, distributors and customers. As of December 2, 2008, REACH required that all substances manufactured in or imported into the European Union (EU) above one (1) ton/year be pre-registered to the European Chemicals Agency (ECHA). Pre-registration allows material suppliers to benefit from special transitional arrangements while ensuring continued supply to the EU market until materials are fully registered. Full registration will be done in a tiered approach from 2010 until 2018.  

Current REACH Status

Cytec pre-registered all substances manufactured in or imported into the EU by its different Legal Entities in 2008. Cytec has also successfully completed the registrations for the 2010 and 2013 deadlines and is actively working to meet the registrations required in the next deadline of 2018.  

We continue to assess the impact of REACH on our product portfolio. Cytec is committed to providing our customers clear and timely feedback regarding the registration status of substances and products we supply.

Only-Representative

Cytec pre-registered and will register many substances used in our products made outside of Europe via an Only-Representative (OR). This has the potential to relieve our customers and downstream supply chain from their registration obligations related to importation of Cytec products. With the OR arrangement, customers are regarded as downstream users of the Only Representatives. If you have not communicated with us previously on this subject and are interested in benefiting from the OR arrangement, please contact your local sales representative.

Substances Subject to Authorization

Annex XIV of the REACH legislation (Substances Subject to Authorization) has been published by ECHA and this list is still growing. Cytec continues to track updates to the Annex XIV list and communicate to our customers in line with its obligations under REACH regarding the inclusion of such substances in any of Cytec's products. 

Safety Data Sheets

Format Changes according to Annex II of REACH

Cytec already implemented the format of the last amendment of REACH Annex II, in line with the requirements of Annex I to Regulation (EC) No 453/2010. All revised safety data sheets (SDS) are being re-published under this new format. 

REACH Registration Numbers
  • For substances registered by Cytec, the REACH registration numbers have been added in section 1 of the SDS.
  • For substances registered by others, the REACH registration numbers are being added in section 3 of the SDS.  The last four digits may be omitted in line with Regulation (EC) No 453/2010 (Annex I, 1.1)
Exposure Scenarios

Cytec provides extended safety data sheets (eSDS) with the following exposure scenarios: 

  • For all substances registered by Cytec above ten (10) tons/year that are classified as dangerous, we will update our SDSs into eSDSs with exposure scenarios. The identified uses are disclosed in our eSDS
  • For substances registered by others, Cytec will pass on the exposure scenario in an eSDS
  • For substances registered below ten (10) tons/year and for notified substances ("old" ELINCS), a chemical safety report is not required under REACH as long as they do not reach the next tonnage threshold. The creation of an eSDS with exposure scenarios is also not required per REACH article 31.7
  • For substances that are not yet registered, Cytec will proactively contact companies in the supply chain during the completion of the registration dossiers to gather data on their intended uses and, if needed, the exposure data for the products involved
  • For mixtures/preparations, Cytec will communicate any major change that is made available to us from our suppliers. We consider a major change as any new information that affects the use, the classification and/or the Risk Management Measures (RMM) of the mixture. In cases where there is not a major change to the SDS, Cytec intends to update the SDS of its mixtures/preparations after a complete set of exposure scenarios is received. Please note that an exposure scenario annex to the SDS is not required for a mixture unless a chemical safety assessment was conducted on the mixture itself
Substances of Very High Concern (SVHCs)

When a new SVHC is added on the candidate list, Cytec's SDS will be updated within a period of two months. 

Implementation of CLP (Regulation (EC) No 1272/2008 and amendments)

All Cytec products being substances (not mixtures) are classified and labeled according to CLP. Their SDSs contain the classification according to both CLP and the old Dangerous Substance Directive (DSD, Directive 67/548/EEC). 

For mixtures, the legal requirement is more complex. The CLP classification must be mentioned as of 1 December 2012 for those substance(s) for which the CLP classification has been provided to us (according to Regulation (EC) No 453/2010 (Annex I, 3.2.3.) and no later than 1 June 2015 for all others.

Cytec actively has been working towards adding the CLP classification on all SDSs re-published after December 2010 so that both CLP and DSD classification are provided. 

Cytec's REACH Teams

Cytec has a REACH Team to oversee overall strategic, cross-business and inter-regional issues. The team consists of our senior corporate product regulatory and stewardship managers, business team representatives and representatives from the toxicology and procurement departments. 

Each Cytec business unit will have specific strategies for those substances that we directly manufacture or import so that we can convey our intentions as clearly as possible to our own customers.

A dedicated procurement team is implementing a structured approach to raw material sourcing. We are seeking confirmation from our raw material suppliers regarding their intentions to register our raw materials. In addition, our supply chain organization is engaged with both our plants and the procurement team to ensure continued supply of our products to our customers.

Active Communication

Cytec is actively communicating across our value chain about our approach to REACH. Our customers contact us seeking confirmation that we have submitted pre-registration or authorization records for a particular substance, and we communicate with our suppliers so that they better understand how customers use their substances in order to conduct risk assessments and recommend safe handling measures.