MTI’s Pre-registration Activities under REACH
What is REACH?
REACH is the name of a regulation passed by the European Union in 2007 to streamline and improve the former legislative framework on chemicals of the European Union (EU). REACH places greater responsibility on industry to manage the risks that chemicals may pose to the health and the environment. REACH is an acronym for the Registration, Evaluation, Authorisation and Restriction of Chemicals. This regulation became effective throughout the European Union (EU) on June 1, 2007. REACH applies to all companies that manufacture chemicals in the EU or import chemicals or articles containing chemicals into the EU. REACH requires these companies to identify the environmental, health and safety risks of each chemical as well as specify proper safety measures to protect those who use these chemicals in downstream applications. This information will be made public through a registration process. The European Chemical Agency (ECHA) is the agency set up to oversee the process and manage the registration data.
REACH is being implemented in a phased approach. Importers and manufacturers of existing chemicals who pre-register their substances before 1 December, 2008 will have 3.5 to 10 years to submit the full registration, depending on the quantity of material imported or manufactured in the EU. Companies that do not pre-register must complete the registration process before the end of 2009. If a chemical is not pre-registered or registered within the specified timeframe, it may not be manufactured in or imported into the EU.
How is MTI responding to REACH?
MTI has developed a REACH Implementation Team to evaluate the impact of this new law for all of our operations and our customers. The Team includes operations, sales, research, supply-chain, environmental, health & safety and legal experts from all of our businesses.
How are MTI’s products regulated under REACH?
The impacts of REACH upon each business and product group are summarized below:
Specialty Minerals Inc Uncoated Limestone and Barretts Minerals Inc Talc products
Specialty Minerals Inc (SMI) mines and processes limestone products at operations in the US. Barretts Minerals Inc (BMI, a wholly-owned subsidiary of SMI) mines and processes limestone and talc products at operations in the US. Many of these products are either shipped directly to the EU or are sold to downstream users who ship their products to the EU. Limestone and talc products are considered "minerals which occur in nature, if they are not chemically modified" and therefore are exempt from registration (Section 7 of Annex V).
Specialty Minerals Inc Uncoated Precipitated Calcium Carbonate products
SMI produces precipitated calcium carbonate (PCC) products at facilities in Adams, Massachusetts, USA; Birmingham, England; and numerous other locations in the EU.
The Birmingham facility has completed pre-registration of the calcium oxide and PCC products produced at this location. The UK facility has also pre-registered calcium hydroxide, since calcium hydroxide is classified as an on-site isolated intermediate for the production of PCC. The submission number of the pre-registration of the Lifford PCC products is GK204712-49. The Birmingham facility has also been authorized to act as the Only-Representative for the Adam facility and has completed the pre-registration of the PCC from Adams. The submission number of this pre-registration is QJ229688-15.
Finally, the Birmingham facility has completed pre-registration of all PCC products and calcium hydroxide intermediates produced by SMI’s various EU legal entities owning the European satellite PCC facilities. The submission number for each of these legal entities is provided in the table below.
Legal Entity | Submission Number | Facilities Covered: |
Specialty Minerals Nordic Oy Ab | FS241145-32 | Äänekoski, Finland |
Specialty Minerals France S.P.A.S | SD239126-43 | Docelles, France |
Specialty Minerals | YH241504-33 | Schongau, Germany |
Specialty Minerals Poland sp. z.o.o. | TW240023-19 | Kwidzyn, Poland |
Specialty Minerals Portugal | YK240180-36 | Figueira da Foz, Portugal |
Specialty Minerals Slovakia spol. S.r.o. | YG240718-23 | Ružomberok, Slovakia |
Specialty Minerals GmBH | SS241685-05 | Walsum, Germany |
Specialty Minerals Inc Coated PCC, Limestone and Talc products
Coated mineral products, including coated PCC, are classified as mixtures (preparations) and do not require a separate registration. This interpretation is based on guidance from the European Industrial Minerals Association. SMI has ensured that the suppliers of the individual coating components have met their registration requirements. SMI will update our Material Safety Data Sheets as new information is obtained from our suppliers.
Barretts Minerals Inc Optibloc products
Barretts Minerals Inc (BMI, a wholly-owned subsidiary of SMI) produces a family of coated and uncoated mineral products under the Optibloc® name. With one exception (Optibloc 300) these products are mineral-based mixtures that have not been chemically modified. As a result, the uncoated fraction of these products is exempt from regulation under Annex V, Section 7 of REACH. SMI has ensured that the suppliers of the individual coating components have met their registration requirements. SMI will update our Material Safety Data Sheets as new information is obtained from our suppliers.
BMI’s Optibloc 300 product is an amorphous silicate material produced at the Bay City, Texas facility. SMI’s Birmingham facility England has been authorized to act as the Only-Representative for Bay City and has completed the pre-registration of this product. The submission number of this pre-registration is JR366556-09.
Minteq Refractory products
Minteq’s European operations produce monolithic refractory products and refractory shapes that are used in the iron, steel, non-ferrous metals, minerals processing and glass markets. Minteq's refractory products are classified as mixtures (preparations) and therefore do not require separate registration. Minteq does not import or produce chemical substances in the EU, with the exception of magnesia, which is discussed below. Minteq has ensured that all suppliers of the individual components are meeting their registration requirements and has verified that these suppliers will include Minteq’s use and the use of our customers in their safety evaluations.
Minteq’s European operations also import magnesia from non-EU locations, including Minteq’s subsidiary magnesia producing firm in Turkey, Asmas. Recently, the European Union specifically exempted magnesia from the requirements of REACH (see Commission Regulation Number 987/2008). This exemption is contained in the revised Annex V, Section 10 of the REACH regulation. However, there is some confusion regarding the exact scope of this exemption. As a result, Minteq has pre-registered the magnesia that is imported from Turkey to the EU using Minteq’s Cork, Ireland plant as the Only-Representative. The submission number for this pre-registration is KT365962-04.
Minteq also produces monolithic refractory products from outside the EU that are imported into the EU. All of these products are preparations. Minteq is developing documentation to prove that all products shipped to the EU from outside the Union will contain only raw materials that have been properly pre-registered or registered under REACH.
Minteq Calcium Metal and Metallurgical Wire products
Minteq produces calcium metal at a facility located in Canaan, Connecticut, USA. Minteq’s facility in Hengelo, Netherlands also imports calcium from both the USA facility as well as other companies in Russia and China. The Hengelo operation has pre-registered calcium metal as an importer. The submission number for Hengelo’s pre-registration is FU397239-02. Minteq’s Cork, Ireland plant has been authorized to act as an Only-Representative to pre-register the calcium that is produced at the Connecticut facility. The submission number for Cork’s pre-registration is RJ598854-05.
Both Hengelo and Connecticut also produce various powder-filled alloy metallurgical wires containing a variety of substances and preparations. Minteq will ensure that the substances contained in the wire or preparations are properly pre-registered or registered by the producer or importer.
Minteq Pyrolytic Graphite products
Minteq produces a variety of synthetic graphite (Pyrolytic Graphite) and silicon carbide products at a facility located in Easton, Pennsylvania, USA. Minteq’s facility in Hengelo, Netherlands has been authorized to act as an Only-Representative to pre-register these products. The submission number for the pre-registration of synthetic graphite is SF397514-25. The submission number for the pre-registration of silicon carbide is YA398033-38.
Who can we contact for more information?
For further information about MTI's REACH Implementation plans or for information about a specific material, please contact us at the following email addresses:
SMI_REACH@mineralstech.com
REACH.MINTEQ@mineralstech.com
Additional sources of information
The following links provide further details on various aspects of REACH:
European Chemical Agency Website
http://echa.europa.eu
Industrial Minerals Association – Europe. This website contains a link to articles and information on the status of various minerals, including limestone and talc, under REACH
