Outline of REACH Regulation and Our Activities to Date

What is REACH Regulation?

Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) refers to European regulations that came into force in June 2007 and have been applied since June 2008, ensuring a high level of protection of human health and the environment, while maintaining and strengthening competence in the chemicals industry in the European Union (EU).

REACH mandates that companies manufacturing or importing chemical substances placed on the EU market amounting to one ton or more per year must register those substances in a succession of steps. Meanwhile, different business concerns that register equivalent chemical substances must jointly prepare registration documents and apply for registration. Once registered, the European Chemicals Agency evaluates the data that has been submitted and assesses methods of safety management. Among these substances, specific hazardous substances are designated as requiring authorization. They are approved for use in the EU only when the authorities judge that the risk to public health and the environment of using the substances are managed appropriately. Accordingly, these regulations clearly demand that businesses conduct extremely complicated and extensive chemicals management.

REACH also obligates all companies in the EU that handle chemical substances (manufacturers, importers, and users) to properly manage them based on risk assessment, maintain the management processes, and exchange information among all members of supply chains.

The MCC Group has been working to comply with REACH provisions, accordingly recognizing two priority issues in particular of: 1. forming a Substance Information Exchange Forum (SIEF) and thereby facilitating communication, and 2. engaging in dialog with our partners in the supply chain.

Process flow to REACH registration

Process flow to REACH registration

Activities to date

1. Building project organization for the Mitsubishi Chemical Group to comply with REACH

REACH is extremely complicated and requires extensive knowledge and comprehension. In some instances, one company alone may not fully comply with the regulations. Therefore, in 2006, Mitsubishi Chemical configured the MCC Group REACH Project, a cross-sectional organization of the Mitsubishi Chemical Group. The organization aims to strengthen knowledge and comprehension on REACH through sharing of information, and the Environmental Safety and Quality Department of Mitsubishi Chemical serves as its secretariat. This organization framework has enabled us to complete registrations according to plan, in regard to all substances with 2010 registration deadlines and all substances with 2013 registration deadlines.

Organization of MCC Group REACH Project

Organization of MCC Group REACH Project

2. Held briefings for the entire Mitsubishi Chemical Group for explaining REACH legislation and its guidance, as well as ways to deal with it

The project secretariat has held internal workshops every two or three months to deepen understanding of the extensive REACH regulations and the different kinds of guidance issued by the European Chemicals Agency (ECHA) for ensuring compliance with REACH. To fully comply with REACH, each concerned party needs to think of specific measures and take action, so the internal workshops hold discussions while proposing ways to communicate with customers, specific items in preparing for registration and other matters of caution, in addition to explaining the provisions. The internal workshops had been held 31 times as of the end of fiscal 2012.

3. Established a helpdesk for Departments and Group companies to consult with

Substances need to be dealt with one by one in the registration work required for REACH. Since procedures and issues differ with each case, the project secretariat offers individual consultation in serving as a helpdesk for the Mitsubishi Chemical Group, and answers customers' questions and provides them with explanations.

4. Opinion exchange with an only representative about registration activities and current situations in the EU

For a manufacturer from outside the EU, an only representative is essential not only for complying with REACH but also for maintaining and expanding business in the EU. The Mitsubishi Chemical Group exchanges detailed information about specific action items and plans for registration with the only representative, and has participated in the formation processes of the Substance Information Exchange Forum (SIEF) on substances to be registered and technical discussions held therein.
In the beginning of 2011, we started to prepare for the registration of substances with annual imports into the EU of less than 1,000 tons and with registration due in 2013. We are proceeding steadily with the preparations by exchanging information with operational divisions and only representatives under REACH regulation responsible for the individual subject substances. In recent years, we have been communicating closely with only representatives under REACH regulation to ensure compliance in such aspects as responses to requests from ECHA for the submission of information, the registration of new substances, and responses to new businesses.

5. Information exchange among members of supply chain

To comply with the REACH regulation, the key issues are in how rationally and efficiently we can collect information on uses and applications of substances in Europe, which is necessary for registration. We have almost no experience in information exchange among members of the supply chain, which starts with raw material manufacturers and reaches the final users via manufacturers, retailers and logistics operators. Currently there are no official guidelines or tools, so we have endeavored to exchange information with customers in relation to REACH, at the same time explaining the REACH requirements to them and taking inventive actions such as generalizing information on uses and applications. We will continue to undertake these activities proactively.

In addition, each time an additional SVHC2 is published, the Mitsubishi Chemical Group conducts detailed research on SVHCs content of products it exports to EU and provides information to importers or customers.

6. Cooperating with activities of chemical and other industrial organizations such as Japan Chemical Industry Association

Mitsubishi Chemical participates in the working group of the Japan Chemical Industry Association for dealing with REACH, in efforts to understand the provisions and find solutions to questions and issues. Also, with the aim of making useful information available through our initiatives pertaining to REACH regulations, we strive to communicate as much information as possible and pursue shared awareness in this regard through active participation in lectures offered by various industrial associations.

7. Information exchange for registration work through domestic consortium activities

In relation to the registration of certain general-purpose chemical substances, some of the companies in our industry involved with registration have established several domestic consortiums for information exchange. Mitsubishi Chemical has also presented opinions at consortiums in the EU, as a domestic consortium leader for certain substances. This made it possible for us to complete the registration procedures for existing substances without any trouble by the registration closing date of November 30, 2010, fulfilling the aim of these activities.
2. Substances of very high concern (SVHC): SVHC refers to substances that are selected from among those that are carcinogenic, mutagenic, toxic for reproduction, etc. and that need to be subject to high-level control throughout the EU through supply chains. A total of 84 substances are designated as SVHC as of the announcement made on June 18, 2012.