REACH and its effects on IGT Testing Systems
With REACH the producer or importer of chemical substances is made responsible for the communication of safe use, handling, storage, transport and disposal of substances. The influence of REACH (Registration Evaluation, Authorization of Chemicals) throughout the production chain is tremendous. The Dutch company IGT Testing Systems reports from its experience in handling this directive and its consequences.
Written by Wilco de Groot
Starting 31 May 2018 most chemical substances on the market in the EU have to be registered under REACH. Obligatory in all EU countries REACH is applicable to manufacturers, importers, distributors and end users of chemicals. Each of these categories has a different role within the chain.
Consequences of REACH
Many companies, in particular Small and Medium Enterprises (SME’s), have seen the consequences of REACH. With headquarters in Almere, The Netherlands, IGT Testing Systems produces and sells test equipment and related equipment and materials, to test paper and other printing substrates, printing inks and print results on a range of aspects and properties.
The influence of REACH throughout the chain is tremendous. Based on the evaluation of the risks for health, safety, toxicity, environment etc., the ECHA (European CHemicals Agency) can add limitations or additional requirements to the substance, its use, the import or production, or ultimately forbid the use within the EU. There are exceptions for some substances, e.g. radioactive or waste materials, which are covered by separate legislation.
In the year REACH was introduced (become effective in 2007), one large chemicals manufacturer claimed, at a conference, to produce about 122.000 chemical substances and he expected that by 2018, the year of complete implementation of REACH, this would be reduced to no more than about 17.000.
This would be done by stopping production of some products, moving production to non-EU countries, sell-off the production (plants) to others, find equivalents etc.
Note that all materials are (made of) chemical substances. Paper with its coating, additives, chemicals needed to produce the paper, e.g. for dewatering, or to make it writable or printable, are all up building bricks.
Inks and substrates
In inks, there are many additives to give the ink the properties required for the specific printing process. The same with substrates, to change surface properties for good adhesion, quick drying, optimal colour reproduction, functional properties. Any change in one of the chemicals involved can have consequences for the total product.
Another issue of the registration is volume. In many cases the dangers for the environment or other hazards are registered based on the regular sales volumes: barrel, container, truck load, trainload etc. It seldom mentions small volumes like those used on a laboratory scale like in IGT’s case, 50-100 ml, and thus formally the company is obliged to conform to all regulations for these large volumes. This is not feasible nor realistic. A discussion with the suppliers seldom ends up with the addition of a separate line in the registration which addresses the issue that the requirements can be relaxed for very small volumes.
IGT depends for production on many segments, many of which be they, chemicals or surfaces are standardized, in the earlier mentioned standards or methods and cannot be changed easily or without also changing the standard and without changing the databases of users.
Problems which especially SME’s face, but not just SME’s, are the replacement of certain chemicals by other, equivalent, materials. Generally, these are tested by the suppliers for the general purpose and application. Also, the volume users are informed in time about changes and they are often involved in the testing of the materials to guarantee the proper functionality once it is on the market.
Small volume user
Sourcing the equivalent without further information as being “the same”, often not even recognizable as an equivalent for several of IGT’s products has created huge problems. This includes rollers which suddenly had a 30% to 40% different ink transfer, rubber rollers which could not be coated anymore with a polyurethane lining to prevent ink penetration and rubbers which could not be polished to the smoothness required for our applications. This further includes test inks with changed drying or picking properties, inks with lower viscosity and higher tack and the opposite, metal roller surfaces which became dull and could not be cleaned from ink anymore and several more.
For these issues IGT had to find solutions in cooperation with their partners. For the rubbers they finally found a good solution but at a substantial cost, not only development costs but also much higher production costs.
Solution for inks
For the inks the only solution was to change the range of inks and reduce the choice for the customers. Here it notable that even the ink manufacturer often hardly knows the existence of a small change in their purchased additives on the final product like ours. For some inks this has already happened three times since start of REACH.
A specialty paper for colour conformity tests in the ink industry is not available any more. This paper must be guaranteed optically “dead”, no optical brighteners of whatever kind are allowed in the paper or the coating. As this is a very important part of many test methods IGT decided to develop, based on the specifications of the old APCO paper, a new paper. This is now made to specification for IGT by some partners. The advantage here is that it was possible to find “safe” additives which are guaranteed available for a long time from different chemical suppliers. So this paper can be produced by different mills over a longer time without being dependent on materials suppliers.
Not only Europe is involved
It is not only the EU that is creating these problems for the SME’s. Other countries, USA, China and others, have learned that they have to take protective actions to protect their markets. Where possible slightly differently so that at least double the work has to be done. The list of dangerous goods, potentially dangerous goods and the way of reporting the ingredients of substances are preferably different from each other. So now that the EU has almost finished its measures IGT can start preparing themselves for the other big markets.
BACKGROUND: REACH (Registration Evaluation, Authorization of CHemicals)
With this directive the producer or importer of chemical substances is made responsible for the communication of safe use, handling, storage, transport and disposal of the substances by means of registration and a safety data sheet (SDS) in conformance with the requirements of REACH and its related legislation.
As from 31 May 2018 most chemical substances on the market in the EU have to be registered under REACH. Although it became effective in 2007, the deadline for registration (≥1 t/a) ends in May 2018. This has been decided by the European Commission in Directive 1907/2006, Publication L396.
This article was first published in NarrowWebTech print issue 2-2018, available also as digital version in our online shop.