R E A CHRegistration, Evaluation, Authorization &

restriction of CHemicals

Rajiv Kumar Chaturvedi

Innovation Center, Tata Chemicals Ltd, Pune

Symposium on REACH Regulations & their impact on Export of Chemicals and Articles

New Delhi, April 7, 2011

Why REACH or other NTBs

Basically a country or group of countries enact NTB’s to protect:

– The interest of consumers, citizens• Health, safety, overall well being …….

– National interest• Economic, local industry, level playing field, strategic ……

– Local & Global Environment • Carbon foot print, hazardous chemical substances

Weak or no regulations / weak or no compliance can compromise the interest of a nation, consumers, industry and environment.

REACH: Basics• Regulation was enacted in June 2007, and enforced in June 2008.

• In its first stage (2008) regulation requires the chemical manufacturers in EU, importers and / or non-EU exporters to register the chemicals that they place in the EU market.

• Onus for regulation compliance is on manufactures, suppliers / exporters.

• The REACH regulations enlists chemicals as “Substance of Very High Concern” (SVHC) in articles;

• So far 39 chemicals have been added to this list and another 11are in the consultation stage.

• It is also expected that this list would grow to about 500 chemicals over a period of next few years.

Kumra: 2nd SCAT Meeting Presentation

Challenges before Indian Exporter

• Low or even no awareness about these regulations and their impact.

• Exporters need to certify that the product is SVHC free or theproduct is REACH compliant (SVHC notification 0.1 %wt/wt and not more that 1 ton in a year) is done to European Chemical Agency (ECHA).

• The SVHC list keeps increasing and updated regularly.

• EU Buyer will require an independent accredited verification and inspection system

• Noncompliance will not allow the export to EU markets.

REACH: Impact on Export

• Affected Sectors are: Chemicals & chemical containing products, toys, dyes, textile, leather, handicraft, Specialty Chemicals, Intermediates, Nutraceuticals, nano-materials, additives etc.

• As newer and newer chemical based products are being developed at rather high pace, the list of Substances of Very High Concern (SVHC) is expected to increase.

• Product cost escalation (due to compliance related expenditure) and more quality based competition.

Way forward is sustainable manufacturing

• Increased proactive commitment and emphasis on:– R&D and Innovation

– Green chemistry and catalysis,

– Environmental concerns

– Mitigating Risk

– Safe manufacturing practices

Innovation is at core of Sustainability

Degree of Complexity

Product/ServiceProcess

Business Model

Social Applications

Chemistry: The mother of materials

8

• A variety of chemical transformations forms the very basis of the existence.

• The phenomenal growth of recent material development is mainly due to:

• The extensive use (& abuse) of naturally available mineral resources.

• The discoveries of a variety of man made chemicals / materials.

• However, Chemistry is no longer welcome by society, if not hated.

• Why only chemistry needs to be green, and not other branches of science? • Because chemistry is also known as the mother of Pollution,

Risk, Hazards (air, water and earth)

9

Risk = Hazard x Exposure

Risk elimination / minimization By avoiding / limiting:

• Exposure (Reactive / Curative Approach)– Down stream treatment, disposal, catalytic

converters etc.

• Hazard (Proactive / Preventive Approach)– Green Chemistry, Novel Catalytic Processes, Efficient

separation technologies.

Advantages are welcome, but…

• No takers of consequent disadvantages.

• The onus, and quite rightly so, of clearing the chemical mess all around also rests on Chemists, Chemical Technologists, Industrialists and off course Governments.

• “Samudra-Manthan:

• AMRUT & HALÃHAL” anecdote

May be likened to Modern Scientific churning (development) and industrialization

Role played by Modern Green Chemistry and Catalysis (Catalytic Converters!!)

Mythological Anecdote in modern perspective

Sustainable Industrial Development through Green Chemistry and Catalysis

What is “Green Chemistry” ?““Green ChemistryGreen Chemistry”” is the utilization of certain set of principles and guidelines that reduces or eliminates the use and generation of reduces or eliminates the use and generation of hazardous substanceshazardous substances in the design, manufacture and application of the chemical substances.

Sector Product Waste/Product Waste(tpa) (wt./wt ratio) (tpa)

Oil/Petro 106-108 0.1-0.01 104-106

Bulk 104-106 1.0-5.0 5 (103-106)Specialty 102-104 5 – 50 5 (102-105) Pharma 101-102 10 - 100 102 – 104

R.A.Sheldon: Chem. Tech., March 1994, p.38 Waste formation

Cat

alys

ts u

sage

Green Chemistry…..

"Green Chemistry " is considered an essential piece of a comprehensive program to protect human health and theenvironment.

Green Chemistry

Sustainable

Avoid WasteNon toxic

Safe

Economical

Atom Efficient

Simple

Environment Friendly

Summary and Conclusions CONTD.

• Increase awareness about REACH and similar regulations consistently

• Facilitate the compliance among Chemicals manufacturing sector.

• Change of mind-set: Challenge as opportunity.

• With globalization of business opportunities, the quality, safety as well as affordability of products is no longer compartmentalized as Export Quality and Non-export Quality.

• Hence, the better way is to adopt safe and green products and manufacturing process for sustainable business and growth.

• C.K. Prahlad’s formula: N=1 and R =G.

Summary and Conclusion• Ever increasing emphasis on Green products and Process

through Innovative R&D and Manufacturing.

• More and more interdisciplinary approach (Bio-chemical?!!!).

• Manufacturers need to have longer and sustainable business perspective.

• Increased collaborations among R&D and Industry as well as different sections and sectors.

• Perhaps a leaf from Pharma sector mainly on quality and compliance?!

• More of specialized centers with good networking for analysis ofboth Inorganic and Organic Impurity profiling and Certification.This may also be a good business proposition.

THANKS