Regulatory Information (REACH, GHS/CLP)
Please note that the information below relates to the following product ranges manufactured and supplied by Magnaflux EMEAR:
REACH Registration Numbers
As you are aware, the REACH Regulation (EC) 1907/2006 came into force on 1 June 2007. The first deadline for substances with certain properties (CMR substances, R50/53 substances), as well as substances produced in an annual volume of more than 1000 tonnes, expired at the end of November 2010. As a result, REACH registration numbers were then available for the first time.
However, it cannot be concluded that all substances have already been allocated such a registration number automatically. For manufacturers or importers of low annual production or import volumes of phase-in substances, longer transitional periods apply, some of them until the end of May 2018. These companies may continue to act as suppliers, even if their substances have not been allocated registration numbers yet, provided that pre-registration obligations were complied with. It may take more time before valid registration numbers are available for all substances in preparations/mixtures.
The registration number will normally be communicated through the Safety Data Sheet or in another suitable form in cases where Safety Data Sheets are not required. However, there is no obligation to use an additional channel for the communication of the registration number. The availability of registration numbers alone does not constitute a reason for updating Safety Data Sheets immediately. However, as this will not be the case until weeks or months after the expiry of each registration deadline, it cannot be assumed that the information can be provided in full before the expiry of the last registration deadline in 2018. It should also be noted that Safety Data Sheets with a full set of registration numbers can take even more time to be published.
Pre-registration and subsequent registration under REACH is for substances only and is to be implemented in three phases ranging from 3.5 to 11 years depending on hazard and substance tonnage bands.
Magnaflux EMEAR only manufactures preparations/mixtures and is classified as a ‘Downstream User’. Preparations/mixtures (two or more substances mixed together) are NOT required to be registered. However, as stated above, each substance that goes into a preparation needs to be registered by the Manufacturer or importer of the substance, if the amount manufactured or imported is 1 tonne or greater.
The key activity for our suppliers in the period between June 2008 and December 2008 was to pre-register their substances. As part of this process, we contacted our chemical suppliers regarding their intentions to pre-register the materials that they supply to us. The results of this showed that all materials we use were pre-registered and hence we have not experienced any supply problems.
Some customers have requested pre-registration numbers for substances contained in our products. We would like to make it clear that, at this stage, we are not in a position to provide this information in full, as we do not have this level of detail from our suppliers. Furthermore, as stated above, this is not a statutory requirement.
Where possible, Magnaflux EMEAR is providing REACH registration numbers for hazardous components within Section 3 of its SDSs, and has a programme to ensure that REACH registration number updates are included (see below).
Substances of Very High Concern (SVHC)
If a substance has been listed on the candidate list (SVHC list), this does not necessarily mean that certain uses of the substance are now subject to risks. Their listing may lead to authorisation requirements for certain uses at a later stage. However, this does not constitute an immediate limitation of use. It gives, in fact, rise to a duty to inform as required for hazardous substances throughout the supply chain.
Hazardous constituents are named in Section 3 of the Safety Data Sheet. Further indications under Section 15 of the Safety Data Sheet will not have to be provided before their official listing in Annex XIV of the REACH regulation. There are no further obligations with regard to the Safety Data Sheet for suppliers of mixtures containing SVHC substances. Downstream users do not require a supplier declaration on the ‘absence of SVHC substances’. Moreover, suppliers are not required to inform downstream users on GHS/CLP notifications undertaken. The GHS/CLP notification number, like the pre-registration number, serves for internal use at the manufacturer or importer and for communication with the authorities only.
Magnaflux EMEAR keep an ongoing watch on the substances that are listed on the Candidate List and Annex XIV list and, where appropriate, have taken, and will continue to take, pro-active action to ensure that our NDT materials and articles do not contain substances on these lists.
Safety Data Sheets (SDSs) According to Annex II of the REACH Regulation and GHS/CLP
With the changing European chemical safety regulations associated with both REACH and GHS/CLP, Magnaflux EMEAR are taking appropriate actions to ensure that the information provided on our Safety Data Sheets (SDSs) is both up-to-date and compliant.
For this reason we set up a project to ensure that our SDSs:
- Were brought into line with the Regulation (EU) No 453/2010 Annex I by the 1 December 2012 deadline. This involved the addition of the new subsections within the 16-section EU SDS template.
- Were brought into line with CLP Regulation (EC) No 1272/2008 for the re-classification of ‘mixtures’ by the 1 June 2015 deadline. In addition these SDSs will comply with the Regulation (EU) No 453/2010 Annex II.
- Were updated into line with the Regulation (EU) No 2015/830.
- From January 2017, now include a 24/7 multi-lingual emergency telephone number.
This same project will ensure that appropriate updates are made to our product labels to reflect that changes to the SDS inventory. The timing of these changes will coincide with the dates and timing described above.
Safety Data Sheet version control
Magnaflux EMEAR operates under a system of version control for its SDSs to ensure that it is clear to our downstream stakeholders that which version of an SDS they are referring to. Our system identifies the version of the SDS by the year and the issue number in that year – for example 14.2 would be the second version released in 2014. The revision date and a description of the changes are also described with the SDS.
Please note that updates to SDSs are will only be made when:
- There are regulatory changes that we are required to implement.
- There are changes to information within the SDSs that have been provided to us by our raw material suppliers – for example REACH registration number updates.
- There are changes that come about as a result of a change to a raw material – for example, a raw material discontinuation.
Safety Data Sheet language availability
Magnaflux EMEAR has invested in new website technology to allow site visitors to download our SDSs in over 80 languages. Availability of these language translations coincided with the 1 June 2015 deadline for the introduction of CLP format SDSs described above. These SDSs will also be available via your local Magnaflux distributor.
Definitive translations of the SDS inventory are also available in English, German and Swedish.
Current Safety Data Sheet (SDS) inventory
Magnaflux SDSs are available:
- For download via our Magnaflux EMEAR website at www.eu.magnaflux.com.
- Via your local Magnaflux distributor.
The SDSs available for download via our website(s) represent the latest legally compliant versions for our current range of products.
Previous versions of SDSs for products that have been withdrawn from manufacture are available upon request.
As a company, we realise that the chemical regulations within Europe and their affects on our downstream users raise a lot of questions. As a result, Magnaflux EMEAR has provided an extensive resource on:
- Understanding the changes to our Safety Data Sheets and labels – CLP.
- Understanding the changes to our Safety Data Sheets and labels – REACH.
- Understanding the changes to our Safety Data Sheets and labels – REACH/Substances of Very High Concern.
- Chemical risk assessments.
This resource can be found here.
If you have any queries or questions regarding any of the above, please contact us.
For a PDF version of this information, click here.