The EU chemicals legislation for the Registration, Evaluation and Authorization of Chemicals, known as REACH, came into force on June 1, 2007 and has pioneered a new approach to improve chemical safety for workers, for the general public, and for the environment. A key part of its concept is the registration of all existing substances on the market (with the exception of clearly defined exemptions), and it no longer limits registration requirements only to newly introduced substances. All substances imported into the EU above 1 tonne per annum require REACH registration (unless they meet the exemption requirements outlined in Annex IV and V of the legislation). Until December 1, 2008, companies were able to pre-register their previously imported/manufactured substances under REACH. Preregistration allowed companies up to 2018 to complete the full registration process while continuing to market their products.
For more information about the REACH legislation and related guidance documents, please visit the ECHA website.
REACH Status at Air Products
At Air Products, we have been preparing for the REACH legislation since its publication in 2006. Air Products’ REACH compliance project is appropriately addressing all requirements of the legislation at its various stages.
We can confirm that Air Products ensured that all relevant substances have been registered in the appropriate supply chains before the 2010, 2013 and 2018 deadlines. However, please be aware that for many substances which were registered before the 2018 deadline, the information about registration numbers is not yet available for a few products’ components.
Products Covered by the REACH Compliance Project
Air Products’ REACH Product List – Industrial and Specialty Gases
Air Products can confirm that the products listed below meet the requirements of the EU’s REACH regulation and that their components have been successfully registered by Air Products or another actor further up the supply chain, or are manufactured or imported in volumes of less than one metric tonne per year.
|Gases included in Annex IV and V and therefore exempt from the obligation to register|
|Gases successfully registered by Air Products or by another actor further up the supply chain|
|1-Butene||Difluoromethane (R32)||Nitric oxide|
|1-Methyl, 3-butene||Ethylene||Nitrogen dioxide|
|Ethylene oxide||Nitrous oxide|
|1,2-Butadiene||Hydrogen bromide||Pentafluoroethane (R125)|
|1,3 Butadiene||Hydrogen chloride||Propylene|
|1,3-Propadiene||Hydrogen sulphide||Sulphur dioxide|
|Ammonia||Methyl acetylene||Sulphur tetrafluoride|
|Carbon Monoxide||Methyl chloride||Tetrafluoroethylene (R1114)|
|Carbonyl sulphide||Methyl mercaptan||trans-Butene|
The Air Products REACH compliance program allows Air Products' legal entities to import the products listed above to EU countries or manufacture them in EU. When purchasing these products, EU customers are then considered downstream users and do not need to register.
Important Notice for Non-EU Based Customers
As global supplier, Air Products is offering some products on a global basis. Our customers may purchase these materials outside of the EU and subsequently import these as is or as part of a formulation into the EU. An importer of these materials into the EU must follow all REACH requirements defined in the regulation for all substances contained within the product. The fact that product may be included in the list of products planned to be covered by Air Products‘ REACH Compliance Project does not automatically free other importers from REACH, i.e., we may have registered all the substances, but not necessarily the non-EU supply chains in question.
However there are mechanisms defined in the legislation which can allow us to cover imports of our customers through nomination of an Only Representative. If you are interested in possible coverage of registered products by an Air Products nominated Only Representative, please send your inquiry to our REACH Team. We will evaluate your inquiry and inform you if the coverage is possible.
Substances of Very High Concern (SVHCs)
SVHC substances include CMR’s (Carcinogen, Mutagen and Reproductive Toxins), PBT’s (Persistent, Bioaccumulative and Toxic), vPvB’s (very Persistent and very Bioaccumulative), or substances representing equivalent concern (e.g., endocrine disruptors and respiratory sensitisers). These substances can potentially be included in Annex XIV and be subject to authorisation in the future. ECHA is continuously working on updates of the candidate list of substances for inclusion into Annex XIV and on the publication and updates of the Annex XIV itself.
Air Products continues to track updates to the Annex XIV list and proactively communicates to those customers purchasing products containing these substances in line with its obligations under REACH regarding the inclusion of such substances in any of Air Products’ products.
Air Products will keep such customers updated on our future plans for any products which will become subject to Authorisation. We will also support customers in the process of transition to alternative products, if necessary.
For the current SVHC list, please refer to the European Chemicals Agency (ECHA) website.
Please be aware that substances exempted from the obligation to be registered by Annex IV and V are available for any use unless limited by other regulation. These substances do not require communication of identified uses to the supplier because it is not necessary to develop exposure scenarios for them. Most of the common air gases supplied by Air Products are exempted by inclusion in Annex IV or V as shown in the table above.
Safety Data Sheets and REACH
Where registrations have been finalised, we are in a position to update our SDSs (Safety Data Sheets) as required with a registration number and new information on safe use. If you do not see this information in one of the SDSs, it means that we are still working on the update or the product has not yet been registered or is exempted from the obligation to be registered.
Classification, Labelling and Packaging (CLP) Regulation
The European Classification, Labelling and Packaging regulation, referred to as CLP (Regulation No. 1272/2008) is closely related to REACH. We can also confirm that we work to maintain compliance with this regulation. We have implemented the following aspects:
- We have classified all pure substances and mixtures according to CLP criteria;
- When required, these classifications have been notified either by Air Products or our suppliers to ECHA;
- All products are properly labelled according to CLP regulation; and
- SDSs are updated to show classification and labelling information according to the CLP requirements.
For more information about the CLP regulation and related guidance documents, please visit the ECHA website.