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Inside REACH

By: Jeb Gleason-Allured, Editor
Posted: March 9, 2009

page 2 of 2

REACH requires data cost sharing “to be carried out in a fair, transparent and non-discriminatory way. … It is up to the registrants to decide and agree on how the costs for the test should be documented.” The question remains: What exactly is fair, transparent and non-discriminatory? “In our consortia we hired a lawyer to write down the agreement [among members], so that should take care of these concerns,” explained Theewis. He believes that these members generally are moving forward with a cooperative mindset in determining the best data and sharing it. While the larger companies that manufacture a wide range of materials tend to have the most extensive data and expertise in dealing with REACH issues, Theewis has been very impressed also with the level of engagement by smaller players.

Complicating matters, Theewis said, customers that indirectly import substances to Europe have asked IFF to help them assign only representatives. However, this would create a huge and daunting administrative issue for the company. “You need to know which fragrance materials they’re bringing in, and how much,” he explained. These customers may ask for IFF to graft their tonnage (since IFF has already preregistered the material in Europe) onto their own totals—however, under the rules of REACH, this is not a simple matter, and liability needs to be carefully managed. By default, each importing company must separately preregister for its own tonnage figures. Even companies the size of IFF have come to realize that they are first and foremost fragrance houses and not regulatory consultants. Customers are increasingly accustomed to their suppliers taking the initiative on regulatory issues. However, under REACH this scenario is not practical. “It’s very complex. It takes a lot of time to explain to people,” says Theewis. Overall, how well have customers been keeping up with REACH? “It really depends, company by company.”

At the time of the discussion, with preregistration coming to a close on Nov. 30, 2008, Theewis was focused primarily on that segment of the program. However, he noted that the company, as end-usage reports came in from customers, could find some surprises with regard to end-use of the raw materials they manufacture. “It provides better insight into how the product is used. If there’s a use that is hazardous we can advise against it. On the other side, customers will learn more about the substances in their fragrances, what the safety of those products is.” That knowledge will trickle down to retailers and consumers, he added. “Consumers under REACH have the right to request information about ‘are there any substances of concern in the product I’m going to buy?’ The retailer has 45 days or so to react. All of those things will hopefully help stimulate consumer confidence.” In the end, the positive outcome for the industry is that consumers will come to better understand that natural does not necessarily equal safe and synthetic does not equal hazardous.