Summary and conclusions

Forberedelser til REACH og udvikling af relevant kompetence inden for tekstilindustrien

In cooperation with DHI, the Federation of Danish Textile & Clothing (DTB) has carried out a project for the Danish Environmental Protection Agency with the aim to prepare the companies within the association for the requirements under REACH. The project ran from September 2006 to March 2008 with participation of five enterprises within this line of business. The participating companies are affected by REACH in a way that is typical for many companies in Denmark, i.e. as ‘downstream users’.

During the project, the companies were rendered concrete assistance with their preparations for fulfilling their obligations under REACH and the project activities were mainly focussed on concrete dialogue and dissemination through meetings at the companies. In general, the project comprised the following activities:

Introduction to REACH at an introductory seminar
Targeted consulting of the companies - including communication in the supply chain (both suppliers and customers), use of the ‘REACH Screening Program’ and calculation of the 0.1% limit in articles for substances of very high concern
External dissemination in the form of a closing seminar open to all enterprises within the association and other interested parties

Both before and at project start, more participants expressed their anxiety and confusion about the new regulation, which confirmed the relevance of the project. For the participants, the introductory seminar provided an overall knowledge of REACH and the project, which was used as a starting point for the subsequent targeted dialogue about the consequences of REACH.

At the individual opening dialogue meetings, importance was attached to the companies’ understanding of the relevant aspects of REACH and to an identification of their roles and obligations. Before the first meeting, the companies had started mapping the raw materials used (chemical products and substances) and, at the meeting, priorities were attributed so that raw materials hard to substitute, raw materials requiring long time to modify use and raw materials used or bought outside the EU were singled out. All of the companies found it relevant that the consultants composed a letter for the large primary suppliers common to all of the companies. We had hopes that, in this way, the project participants would obtain more information on the ingredients of the raw materials.

At the following dialogue meetings, the result of the common letter addressed to the primary suppliers was discussed. Not many responses had been received and of these, only a few suppliers had answered the questions. The companies’ lists of raw materials used (broken down to substance level, if possible) were screened for potential PBT, vPvB, CMR and endocrine disrupting substances and the consequent results were discussed with the companies. For raw materials containing this type of substances, the companies should start considering substitution and/or calculating whether the substance will be present with more than 0.1% in the final product.

Before the last dialogue meetings, an information sheet about article producers’ obligations under REACH had been elaborated and forwarded to the companies. At the meetings, the information sheet was discussed. The lists of raw materials used had been updated and screened again. With the companies, for which substances of potentially very high concern constituted more than 0.1% of their final article, examples of information texts and methods for the articles were discussed. Another subject touched on was the contents of a potential notification to the European Chemicals Agency (ECHA) (when these substances are used in amounts exceeding 1 ton per year).

During the project, the companies learned how to screen their own chemicals by use of the tool ‘REACH Screening Program’, which is a help tool for mapping of chemicals and for assessing which of the company’s chemicals are covered by REACH and how. This tool was developed by DHI under another project for the Danish Environmental Protection Agency, i.e. “Development of competence and tools for implementation of REACH focussing companies within cleaning products and cosmetics”.

An example of an exposure scenario from RIP 3.2-2 (meanwhile published as ECHA’s Guidance on Information Requirements and Chemical Safety Assessment) was studied in order to prepare the companies for their obligations when eventually they receive exposure scenarios. Finally, it was discussed whether the companies felt prepared to continue their preparations and to cope with future obligations under REACH, and questions were answered, if any.

The project was closed with a workshop arranged in cooperation with the Federation of Danish Textile & Clothing. The aim of the workshop was to disseminate the project results and to supply new information on specific REACH aspects.

In general, the benefits to the companies of the project are considered to be:

Knowledge of the most important aspects of the REACH regulation
Identification of the roles and obligations of the companies
Elucidation of specific problems regarding REACH in the companies
Concrete methods for the REACH preparations regarding mapping, communication and knowledge sharing in the companies
A short, easily accessible overview of article producers’ obligations
Mapping and screening of the company’s chemicals assisting in the prioritization of the further work with REACH

For the participating companies, the project has provided a substantial knowledge of the influence of REACH on their companies and of ways to acquire the information needed. They have started their preparations - e.g. got a good grasp of how the different chemicals are affected by REACH, how future deliveries are secured, the most flexibly way of meeting the new requirements and their obligations regarding communication up and down the supply chain. The final preparations lay ahead and, afterwards, the fulfilment of the obligations under REACH where the participants can really draw on the knowledge and tools that they have acquire during the project.