REACH - Frequently
Asked Questions
For more
detailed information about the REACH Regulation, please
visit the
European
Chemicals Agency (ECHA) Web site:
http://echa.europa.eu/
ECHA
manages and carries out the technical, scientific and
administrative aspects of REACH.
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Can
Cytec ensure customers that we will continue to supply
them with our products? |
We have pre-registered all of the substances that we
manufacture or import into Europe by our different Legal
Entities (above 1 ton/year). For the raw materials we
use in Europe, we are working with our suppliers to
ensure that these are also properly registered under
REACH.
We expect to continue to supply products and are
committed to providing our customers clear and timely
feedback regarding the registration status of substances
and products we supply. |
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Will
Cytec offer an Only-Representative (OR) service to non-EU
customers? |
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If you are located outside the EU, Cytec may also offer
its OR services if you intend to start EU
commercialization of products containing substances
purchased from Cytec’s non-EU plants. In these cases,
our OR services may be utilized by our customers outside
the EU. Please do not hesitate to contact your local
sales representative if you wish to set up one of these
arrangements. |
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Is
Cytec willing to disclose confidential information to
downstream users and importers so that they can meet
their REACH obligations? |
The decision to disclose confidential information will
be made on a case-by-case basis. However we recognize
that 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 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.
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. |
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Has
Cytec pre-registered substances used in products made
outside of Europe? |
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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.
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Will
Cytec communicate pre-registration numbers? |
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The pre-registration number
is not mentioned in the REACH Regulation, and there is
no legal requirement to communicate it in the supply
chain. Therefore Cytec has decided not to disclose
individual pre-registration numbers, following the
advice of the European chemical industry association,
CEFIC.
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|
Now
that Cytec has completed pre-registration of
manufactured substances, can you give a firm commitment
that you will also complete the full registration? |
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At this stage we plan to
complete the registration of all our products in
accordance with the schedule provided by the
legislation. There is a possibility that despite our
efforts, supply conditions could change between now and
the long-term registration deadlines of 2013 and 2018,
resulting in some products not being registered as
currently planned. Please be assured that, in such
event, Cytec will make every effort to give as early
warning as possible to manage such a transition.
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When
will Cytec complete full registration of its products? |
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It is too early at this stage to
give a precise timetable for full registration. Cytec
will comply with the deadlines set by the legislation.
The deadlines for specific substances can change when
the volume changes or if the classification of the
substance is changed. Different components (substances)
of the same product may be registered at different
times. The overall product is not completely covered
until all components are registered.
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Are
there any of Cytecs’ substances likely to be Substances
of Very High Concern (SVHC) within the meaning of REACH? |
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Cytec continues to track
updates to the Candidate list and the Annex XIV list and
communicate to its customers in line with its
obligations under REACH regarding the inclusion of such
substances in any of Cytec’s products.
The term SVHC is not defined within REACH, but is
generally accepted to include CMRs (Carcinogen, Mutagen,
and Reproductive Toxins), PBTs (Persistent,
Bioaccumulative and Toxic) and vPvBs (very Persistent
and very Bioaccumulative). These substances may
potentially be included in future Annex XIV candidate
lists - please check our current SDSs to identify
whether the products you currently purchase contain any
SVHC substances.
Return to main
REACH page |
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| Cytec's Safety, Health and
Environment (SHE) Links |
|
Click here
for Cytec's 2010 Sustainability Report.
Contact Cytec |
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