An interesting article about REACH from Lube Report with the title REACH: a Non-tariff Trade Barrier?. Of particular note is the strategies companies are using to ensure REACH compliancy:
Mick Wragg, Lubrizol’s manager of product stewardship for Europe, pointed out some of the most common misconceptions about preregistration: “My EU affiliate will preregister the substances, so export from our non-EU customers is covered.” Don’t count on it, said Wragg. “Someone else will preregister this substance, so we don’t have to do anything.” Maybe, but the list of preregistered substances will not be published until Jan. 2009, well after the Nov. 30 close of preregistration, warned Wragg. “It’s a natural, harmless substance, so it will be exempt.” Be careful. Only four substances have been exempted so far, Wragg said; one is water…
Because future REACH compliance statements could be conditional on customers providing export information back up the supply chain, Wragg emphasized that additive suppliers could make this a condition of sale…
General Motors, which alone has more than 30,000 suppliers, has set up www.GMreach.com, said Guikema. Ford is requiring suppliers to confirm that they understand and will comply with REACH. And Chrysler is implementing its approach to REACH based on business units affected.
For the full article, click on the link above.
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