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 meeting the first deadline in 2010 and is actively working to meet the registrations required in the next deadline of June 2013.

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.
 

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.

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 SDSs 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 SDS.
•   For substances registered by others, the REACH registration numbers are being added in section 1 of the SDS as soon as we get them from the registrants. The last 4 digits may be omitted in line with Regulation (EC) No 453/2010 (Annex I, 1.1)
•   For mixtures, the REACH registration numbers available to us are being added in section 3 of all SDSs re-published after December 2010. The last 4 digits are omitted in line with Regulation (EC) No 453/2010 (Annex I, 3.2.4).

Exposure Scenarios
Cytec provides extended Safety Data Sheets (eSDS) with exposure scenarios as follows:
•   For all substances registered by Cytec above 10 tons/year that are classified as dangerous, we have already updated 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 as soon as we get this information from the registrant;
•   For substances registered below 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. Therefore 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 in order to gather data on their intended uses and, if needed, the exposure data for the products involved.
•   For mixtures/preparations, Cytec will communicate within 6 months* any major new information which is made available to us from our suppliers. We consider a major change as any new information which affects the use, the classification and/or the Risk Management Measures (RMM) of the mixture. In cases where there is not a major revision to the SDS, Cytec intends to update the SDS of its mixtures/preparations within 18 months* 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 2 months.

* In line with the guidelines of the Downstream Users of Chemicals Co-ordination group (DUCC) on the Revision Management of Safety Data Sheets for preparations/mixtures complying with REACH and CLP Regulations.

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 has 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 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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