2072 Flint Group Statement On REACH

Flint Group completes next phase of REACH registrations

REACH – the European Community Regulation on chemicals and their safe use (EC 1907/2006) – hits another milestone on May 31 st , 2013. In addition to the successful 2010 registrations, Flint Group has provided all registration dossiers for the 100 to 1.000 tons p.a. registration tonnage band to the European Chemistry agency (ECHA) as relevant authority on time and in full. Flint Group as one of the first companies has already received ALL 2013 registration numbers from the authority which underlines the high level of Flint Group handling REACH.
The 2013 REACH registrations were even more complex as the 2010 registrations: This time 3.215 legal entities sent in 9.084 dossiers dealing with 2.923 new substances and 696 substances already registered by other companies in 2010. Due to the lessons learnt out of the 2010 registration and the increasing expectations of ECHA, Flint Groups REACh registration dossiers consist of up to 2.500 pages.
The very high REACH registration costs (ECHA fees, lab tests…) had already a pricing impact caused by the registrations for the tonnage bands done so far (1.000+ tons p.a. in 2010 and 100 to 1.000 tons p.a. in 2013). Even if we talk about high costs for the industry the availability of raw materials in general has not changed significantly.   However we anticipate that the costs for registration will have a more significant impact for the next registration phase in 2018 (covering the smaller quantities 1 to 100tons p. a.). Many companies now will need to decide if they will push through the 2018 registration process and will be able to have a reasonable return on investment on those registration costs by increasing either volumes and / or pricing of those materials. In many cases that business case might not look to positive.
Flint Group expects therefore for 2018 a significant number of raw materials in general might disappear from the market just by economical reasons. Flint Group therefore works pro-actively with its suppliers to see how to proceed with the 2018 registrations in order to ensure in an early stage the long term availability of our key raw materials to be able to produce the products our markets require. While we can not be immune for general market movements, we believe that our internal backwards integration on Pigments and Resins will help to secure this goal as this give us both the production capability but more important the in depth understanding of the composition of the raw materials.