Adopted in 2006, REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation. It is a European regulation that aims at improving the protection of human health and the environment from potential risks from chemical substances; whilst ensuring global competitiveness of the EU chemicals industry is maintained. As opposed to previous legislation, REACH places the burden of proof on industry. To comply with the Regulation, companies must correctly identify and manage risks. In turn, chemical producers must demonstrate to the European Chemicals Agency (ECHA) how a substance can be safely used and communicate any risk management measures to their users.
To deliver on such ambitious objectives, the Regulation has put in place a number of processes that have required a huge response from the chemical industry and its value chains in recent years.
A restriction is used to protect human health and the environment from unacceptable risks posed by chemicals. Restrictions may limit or ban the manufacture, placing on the market, or use of a substance. In specific cases, like for diisocyanates, where the product is used in numerous applications, authorities may decide to call for the development of targeted product stewardship initiatives. These will ensure that all workers who interact directly with the substances are both informed and trained in order to manage any risks associated with their handling and close contact.
REACH Restriction on diisocyanates
BAuA, the German REACH Competent Authority (CA), took a particular interest in the respiratory sensitising properties of diisocyanates at the workplace (if not handled properly).
In order to clarify the situation and identify the best policy tool, German authorities decided to conduct a Risk Management Option Analysis (RMOA). The exercise was completed in August 2014 and Germany recommended a more unique restriction route, by proposing mandatory training that would ensure safety in the workplace for workers handling diisocyanates. In October 2015, BAuA formally registered its intention to prepare a restriction dossier. The dossier was formally sent to ECHA in October 2016 and was adopted by ECHA in December 2017.
On 4 February 2020, the REACH Committee voted in favour of the European Commission’s proposal for a REACH restriction on diisocyanates. The Restriction was published on 4 August 2020 applying from 24 August 2023 after a transition period of 3 years.