Future access to raw materials is critical to sustainability………a real measure of viability
How important would it be to your business if certain key raw materials were no longer available to you?
- Would your business be viable or what would you do if your product range decreased dramatically due to the regulations governing the manufacture and application of products? (eg. from from 26 products supplied to many clients to a 2 product range supplied to one key customer, as has happened to a business we know).
ECOS is currently working with clients to ensure that they can plan for the future by knowing about the Regulation, Registration and Documentation requirements they will need to address to ensure that they continue to have access to materials and a product range which can be released to customers .
- We work with our clients to identify their current and future needs which may be impacted by Regulation, Registration and Documentation requirements.
- We then develop and implement structures, procedures and practices to ensure that the business can continue to provide their products to their current and future customers………… a real measure of viability.
An example of regulation requirements which will impact upon the availability of raw materials and products in the near future is the REACH legislation.
- Under REACH Substances of Very High Concern(SVHC) listed in Annex XIV (“Authorization list“) will not be allowed to be used, placed on the market or imported into the EU after a date to be set unless the company is granted an authorization.
- As of April 2013 there there 22 substances on the authorization list (updated in April 2013).
The REACH Regulation requires that ECHA identifies from the “Candidate List” priority substances to be included in Annex XIV of REACH (the “Authorisation List”). There are two key dates of concern:
- The last date of application
- The Sunset Date – the final date where a substance can no longer be used without Authorization
For example the latest date of application for chromic acid is 21 March 2016 and the Sunset Date is 21 September 2017.