Cytec has pre-registered all substances manufactured in or imported into the EU by its different Legal Entities (above 1 ton/year)

We continue to assess the impact of REACH on our product portfolio and will provide our customers more guidance as we approach the various registration deadlines. 

We expect to receive the certification of REACH compliance from all our EU raw material suppliers in the short-term. It is their responsibility to ensure that all substances they manufacture and import into the EU are covered by a valid pre-registration or registration. 

Cytec is committed to providing our customers clear and timely feedback regarding the pre-registration and registration status of substances and products we supply.  The detail in our responses is contingent on our suppliers’ information.

Cytec pre-registered 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.

Downstream users of our substances will need information to ensure their own compliance under REACH.  This includes confirming that their use is covered by the registration of their supplier.  We recognize that downstream users have the right to inform their suppliers about their intended use so that their use can be included in the registration dossier, and an appropriate assessment can be performed.

Cytec is not able to provide detailed information on the Exposure Scenarios and uses to be covered in our registration dossiers. During the completion of the registration dossiers, Cytec will proactively contact companies in the supply chain to gather data on their intended uses and, if needed, the exposure data for the products involved.

We plan to use our updated Safety Data Sheets, which will become available at the time of registration, to provide relevant information needed by downstream users.

Pre-registration numbers are assigned only as an administrative tool during the pre-registration process.  These numbers have no value or meaning to customers or downstream users.  They cannot be used to confirm a product is in compliance with REACH.  Cytec has decided not to disclose individual pre-registration numbers, following the advice of the European chemical industry association (CEFIC).
 

The list of substances which are candidates for inclusion into the Annex XIV of the REACH legislation (Substances Subject to Authorization) has been published by the European Chemicals Agency (ECHA).  However, Annex XIV itself is not expected to be published until sometime late in 2009.  Cytec will continue 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.
 

Cytec has formed a REACH Steering 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, procurement, information technology and legal 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 with representatives from each of our business units 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.
 

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