REACH – a challenge for the automotive industry
REACH, a directive of the European Parliament and the European Council as of December 18th 2006 for the registration, evaluation, approval and limitation of chemical substances, came into effect on June 1st 2007. Chemicals are indispensable in the automotive production. The effects of the complex modifications cannot be evaluated yet.
The REACH directive is one of the biggest law initiatives ever initiated by the EU. It is extremely extensive and highly complex. REACH serves to protect health and the environment and to provide better and more transparent information about chemicals, also to the public. Depending on the annual production or import volume, chemicals in the EU must therefore be registered and/or evaluated. The so-called "especially alarming substances” are subjected to a regulatory approval procedure.
The specified periods of the REACH directive stared mid-2007. The directive must be implemented until 2018. It concerns all chemicals marketed with an annual production volume of more than one ton per manufacturer/importer. This will include approximately 30,000 chemicals.
REACH results in deep interferences in material management
Without chemicals, vehicles cannot be manufactured, as cars and car parts consist of substances, preparations, materials or products. REACH subjects these substances to highly complex legal regulations that imply deep interferences with the material management and the effects of which cannot be evaluated finally at this point.
In addition, companies not only procure chemicals but also distribute the latter, like e.g. lacquers for car repair. Furthermore, products and materials from countries outside of Europe are sometimes imported into the EU, which means that automotive companies can also be importers in the sense of the REACH directive.
The VDA has observed the development of the REACH directive critically right from the start and also informed the automotive companies. The VDA started its information campaign with a REACH event in mid-2007, which was accepted very well. The lectures and the many questions emphasized the relevance of REACH for the automotive industry. However, REACH should not lead to blindfold or overhasty reactions. REACH was compared with a marathon that requires careful preparation.
International guide for the implementation of REACH in companies
The VDA has also published a common guide for the implementation of REACH in automotive companies in cooperation with the American, Korean, Japanese and European automotive association. This guide is available in German, English, French, Spanish, Italian, Japanese and Korean language.
This guide not only serves to describe and explain the most important obligations and tasks imposed by the REACH directive but also to synchronise and coordinate the automotive industry’s activities. A joint interpretation and implementation of the legal provisions shall enable a seamless implementation of REACH across our industry and minimise risks. Simultaneously, the advertent effects on companies in the automotive industry, in particular in terms of competitiveness and internal procedures, shall be reduced as far as possible.
Worries concerning innovations and competitiveness
Risks in relation to REACH can however not be completely excluded. The composition of some chemicals and materials might change in the future and offer different specifications. Other chemicals might probably be omitted. You may have to change your suppliers.
The automotive industry strives to maintain the range of available substances and their applications. Otherwise, innovations could be put at risk, as, in addition to the development of new chemicals, the combination of existing chemicals with resulting new specifications must remain possible.
The effects related to REACH will still bother the automotive industry for a long time. Other challenges include the alignment with new rules and regulations, like e.g. the introduction of a new Globally Harmonised System (GHS) – a global system for the classification and identification of chemicals.
The automotive industry has prepared for REACH in the best possible way, in order to address and successfully complete the resulting tasks. Notwithstanding the foregoing, REACH is not suited to support the competitiveness of the European industry. The effects of REACH on the industry must be observed very carefully. A revision for streamlining and simplifying these complex rules and regulations might be required.