Interflon BV REACH Requirements

“Producer” / “Formulator”

The REACH regulation distinguishes between four primary roles in the supply chain of substances and products. These roles are linked to the activities of the companies that work with these substances and products (manufacturer, importer, user and distributor).

Our primary roles

Interflon BV has the primary role of “downstream user” because we do not manufacture any new chemicals ourselves, but only use chemicals made by others. Within the group of “downstream users”, Interflon holds the role of “Formulator”.
The Interflon sales organisations have the role of "distributor" and "downstream user" (when demonstrating and applying Interflon products). The purchasers / users of Interflon products are, in most cases, considered "downstream users".

According to REACH (art. 3.12), the “downstream user” Interflon BV is required with respect to its employees to:

To comply with the instructions in the MSDS on the safe use of registered chemical substances and work in accordance with the recommended risk control measures during production. In case the MSDS contains an exposure scenario for the use of a product, to introduce the prescribed risk control measures in the internal organisation. If use of a substances has not been included in the registration (non-identified use):

• Inform suppliers of possible new information with respect to hazards, including classification and labelling
• Provide any information that might give rise to doubts with respect to the appropriateness of risk control measures in a received exposure scenario

As a “Formulator”, Interflon has the task of drawing up material safety data sheets (MSDS) for its products to detail identified uses. The MSDS will include relevant exposure scenarios, safety recommendations and measures and other relevant information about the correct use of the product. This applies especially to products that are labelled as hazardous.

If the exposure scenario for use by a “downstream user” deviates from the scenario for identified use included in the MSDS:

• Interflon will draw up its own chemical safety report and bring the use thereof to the attention of the European Chemicals Agency (ECHA) (at a ton limit of 1 ton/year or more).

As a “Formulator”, Interflon is further required, for substances that are subject to authorisation (future appendix XIV to REACH), to:

• Interflon will us the substance according the terms of the authorisation as granted for specific use;
• notify the ECHA of the use of the authorised substance within three months of the first delivery.

Interflon will collect the following information about substances for which no MSDS is provided:

• registration number(s);
• peculiarities with regard to the possible legal restrictions according to the Marketing and Use Directive (until 1 June 2009) or according to appendix XVII (after 1 June 2009);
• appropriate risk control measures;

Interflon BV will also pass information about the authorisation requirements of substances (as on appendix XIV) to other downstream users and distributors in the chain.

Interflon will immediately pass to suppliers any new information about the risks of substances and information which may lead to the adjustment of risk control measures in the MSDS.

Interflon will use substances that are included in appendix XVII according to the applicable restrictions to marketing and use.

• With respect to the dossier assessment by the ECHA:
• conduct additional tests on a substance;
• at the request of the ECHA, provide additional information about a substance.
• store all data about a substance or the preparation thereof for a period of no less than ten years and make these available to the authorities in the Netherlands or to the ECHA on request.

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