REACH Regulation and Responsibilities for Stainless Steel Producers

As a trusted partner of Caffepress, it’s crucial that our overseas distributors and OEM brands understand the complex regulatory landscape that governs the materials we use. One of the most significant regulations impacting stainless steel production is the REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals). This article provides a detailed overview of REACH and the responsibilities it places on stainless steel producers, ensuring you are well-informed about our commitment to compliance and the impact it has on our products and your business.

What is REACH?

REACH is a European Union regulation (EC 1907/2006) designed to improve the protection of human health and the environment from the risks that can be posed by chemicals. It places the responsibility on industry to manage the risks from chemicals and to provide safety information on the substances. The regulation applies to all chemical substances; not only those used in industrial processes but also those in our day-to-day lives, for example in cleaning products, paints as well as in articles such as stainless steel components.

The REACH regulation has several key objectives:

• To protect human health and the environment from the risks posed by chemicals.
• To promote the free circulation of substances on the EU market.
• To enhance innovation and competitiveness in the European chemical industry.
• To progressively replace the most dangerous substances (Substances of Very High Concern – SVHCs) with safer alternatives.

REACH Obligations for Stainless Steel Producers

Stainless steel producers, including Caffepress and our suppliers, have specific obligations under REACH, dependent on their role in the supply chain. These obligations can be broadly categorized as:

1. Registration

Registration is the cornerstone of REACH. Any company that manufactures or imports a substance in quantities of one tonne or more per year must register it with the European Chemicals Agency (ECHA). This registration involves submitting a comprehensive dossier containing information on the substance’s properties, uses, and potential hazards, as well as risk management measures.

For stainless steel producers, this means registering the various components used in the manufacturing process, such as:

• Alloying elements like nickel, chromium, molybdenum, and manganese.
• Any processing aids or additives used during steel production.

Importantly, stainless steel itself is considered an “article” under REACH. Generally, articles do not require registration. However, if a substance is intentionally released from an article during normal and reasonably foreseeable conditions of use, that substance must be registered if it’s present above one tonne per year and no exemption applies. This is less relevant for typical stainless steel applications, but it’s a critical consideration if special surface treatments or coatings are applied that might release substances.

2. Evaluation

ECHA evaluates the information submitted in registration dossiers to ensure that it is complete and accurate. They also assess the hazards posed by substances and evaluate the risk management measures proposed by companies.

This evaluation process may lead to requests for additional information from registrants or even restrictions on the use of certain substances if unacceptable risks are identified. Caffepress and its suppliers actively participate in this evaluation process to ensure continued compliance.

3. Authorisation

Authorisation is required for Substances of Very High Concern (SVHCs). These are substances that have particularly hazardous properties, such as being carcinogenic, mutagenic, reprotoxic (CMR), persistent, bioaccumulative, and toxic (PBT), or very persistent and very bioaccumulative (vPvB). If a stainless steel producer uses an SVHC, they must apply for authorisation from ECHA, demonstrating that the risks are adequately controlled or that the socio-economic benefits of using the substance outweigh the risks, and that there are no suitable alternative substances or technologies.

Although stainless steel itself doesn’t typically contain SVHCs in quantities requiring authorization, the processing chemicals used in its production could. Therefore, Caffepress works closely with its suppliers to ensure that any SVHCs used are properly authorised and that safer alternatives are continuously sought.

4. Restriction

REACH includes restrictions on the manufacture, placing on the market, or use of certain substances that pose unacceptable risks to human health or the environment. These restrictions can apply to substances on their own, in preparations, or in articles.

Restrictions are constantly being updated and expanded, so Caffepress maintains vigilant monitoring to ensure compliance with all relevant restrictions that might affect stainless steel products. This includes monitoring for restrictions on substances used in surface treatments, cleaning processes, or other manufacturing steps.

5. Communication in the Supply Chain

A crucial aspect of REACH is the requirement for companies to communicate information about the hazards and safe use of substances throughout the supply chain. This includes providing Safety Data Sheets (SDSs) to downstream users for substances that are classified as hazardous. Even for articles like stainless steel, information about the safe use and handling of the material must be provided to ensure that downstream users are aware of any potential risks.

Caffepress ensures that all necessary information regarding the chemical composition and safe handling of our stainless steel products is readily available to our distributors and OEM partners. This includes providing relevant sections of SDSs for processing chemicals, as well as guidance on proper handling and disposal of stainless steel scrap.

Benefits of REACH Compliance

While REACH compliance can be complex and demanding, it provides significant benefits for both Caffepress and our partners:

• Enhanced Product Safety: REACH helps ensure that our stainless steel products are safe for their intended use, minimizing risks to human health and the environment.
• Market Access: Compliance with REACH is essential for accessing the EU market. By ensuring that our products meet REACH requirements, we maintain our ability to sell and distribute our products within the EU.
• Improved Brand Reputation: Demonstrating a commitment to REACH compliance enhances our brand reputation and builds trust with our customers and stakeholders.
• Innovation and Sustainability: REACH encourages the development and use of safer and more sustainable chemicals and technologies, driving innovation and promoting environmental protection.
• Legal Certainty: By complying with REACH, we reduce the risk of legal challenges and penalties associated with non-compliance.

Summary

The REACH regulation is a critical framework for ensuring the safe use of chemicals throughout the supply chain. As a stainless steel producer, Caffepress is committed to fulfilling its obligations under REACH, including registration, evaluation, authorisation, restriction, and communication. By prioritizing REACH compliance, we not only protect human health and the environment but also ensure the continued market access and reputation of our products. We encourage our overseas distributors and OEM brands to familiarise themselves with REACH and to work with us to ensure a safe and sustainable supply chain.