Obsolescence and lack of European Economic Area (EEA) market access to chemical products critical to the aerospace industry due to the registration component of European Union’s (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation is a real concern. In accordance with the EU REACH regulation, manufacturers and importers must collect data on the chemical substances they manufacture or import, use this information to assess the risks related to these substances, and establish appropriate risk management measures to control those risks. This information is communicated to the European Chemicals Agency (ECHA) through a registration dossier containing the hazard information and, where relevant, an assessment of the risks that use of the substance may pose and how these risks should be controlled. The deadline for registering phase-in substances with ECHA that are manufactured in, or imported into, the EEA at 1-100 tonnes/year is 31 May 2018 (the deadline for registration in larger tonnage bands was 2010 and 2013).
We are concerned that due to a number of factors, chemical substances in formulations critical to the aerospace industry may not get registered with ECHA and subsequently be removed from the EEA market. To support continuity of supply and continued use of key substances and formulations, we are carrying out activities to identify obsolescence risk due to the registration process.
We recognize that the aerospace supply chain is both extensive and complex. Therefore, we need help from our suppliers, particularly chemical product formulators and EEA importers, to understand registration intent and identify risk. The entire aerospace supply chain will benefit from participating in information gathering efforts.
This work group will develop an approach to help the Aerospace industry manage chemical product obsolescence risk resulting from the 2018 REACH registration milestone. The workgroup will:
- Meet with chemical product manufacturers to understand their registration intent and how they provide required registration information to importers as either a downstream user or registrant.
- Meet with selected chemical product manufacturers and importers to identify which chemical products are at risk of European Economic Area (EEA) market withdrawal.
REACH Registration 2018 Deadline & Business Continuity
- Cover Letter
- REACH Registration 2018 Deadline and Business Continuity Risk Communication Package
- REACH Registration Business Continuity Risk Assessment Questions
- European Chemicals Agency (ECHA) REACH Registration site: https://echa.europa.eu/regulations/reach/registration
- European Chemicals Agency (ECHA) Registration Support site: https://echa.europa.eu/support/registration
- European Chemicals Agency (ECHA) Guidance on Registration (Version 2.0, 2012): https://echa.europa.eu/documents/10162/13632/registration_en.pdf
- European Chemicals Agency (ECHA) Registration Guidance in a Nutshell (2013): https://echa.europa.eu/documents/10162/13632/nutshell_guidance_registration_en.pdf