REACH: A PRIORITY FOR ALL ENTITIES BELONGING TO NLMK Europe
CLP (EU Regulation 1272/2008) lays down new rules on classification, labeling and packaging of hazardous substances and mixtures. The acronym "CLP" means, "Classification, Labelling, Packaging".
- In November 2010 relevant EU NLMK legal entities registered several substances manufactured or imported in quantities above 1000 ton per year in the frame of REACH. On the other side, in December 2010 relevant EU NLMK legal entities notified of several substances because of imports in the frame of the CLP regulation. The reader will discover the details with REACH registration numbers in the specific file of each entity. The substances notified last year in the context of the CLP will be registered by the same legal entity in the frame of REACH either in 2013 or in 2018 depending on their respective tonnage (all between 1 and 1000 tonne per year).
Steel as an alloy has particular properties that are acknowledged in REACH. The assessment of alloys requires specific methods.
NLMK Europe has to submit registration files to the European chemicals agency (ECHA). As recommended by the Regulation, NLMK Europe proceeded in November 2008 to the pre-registration of several chemical substances and namely those present in its steels (see enclosed lists in the files below per legal entity).
This partly precautionary measure allowed NLMK Europe to wait for a clarification in the REACH interpretation:
Semi-finished products of the steel industry (slabs, blooms, etc.) fall under the Reach scope. Therefore, their import does not generate any registration obligation of their constituents for the importer. The unanimous stance of the steel industry in that respect is in the next file inserted, together with the reply of ECHA.
Consequently, the number of substances, which will be effectively registered by the legal entities of NLMK, will probably be shorter than what appears in the preliminary list at the same time meeting the legal obligations.
All NLMK’s European legal entities fulfilled the second major legal obligation of REACH. It was necessary to inform our suppliers before the end of November 2009 about the uses of their substances at our plants. The reader can find in the next table the typical content of the letters that have been sent, together with a file explaining the kind of information included.
We also would like to inform our customers that none of the substances proposed up till now by ECHA as candidate (substances of very high concern) for the list of annex XIV of REACH has been so far detected by our factories in the finished products that the Group is putting on the market. The list of those substances can be found on ECHA’s web site (see the link below).
REACH is progressively integrated in the daily management of our entities. A bridge is built between the Substances, health and safety practices and the environment. By putting the necessary human resources in the implementation of REACH obligations, NLMK intends to reassure its partners on the strict respect for this regulation.
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Feel free to send questions and comments to firstname.lastname@example.org
More information about the position papers of the European steel industry is available on the Eurofer website (European confederation). Furthermore, general information about Reach can be found on the ECHA web site.