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REACH

New EU regulations requiring registration, evaluation and authorisation of nearly all chemical substances supplied in Europe are now in force (REACH). They require a phased approach to registration over the next 9 years, starting with the largest volume substances.

We recognise that REACH is a reforming and radical approach to chemical regulation and we are playing our part in ensuring that the industry achieves the ultimate goal of ensuring there is sufficient information on chemicals made and used within the EU. There will be a demand for higher levels of proof of performance and environmental acceptability for novel products, but we see this as a positive move for the high-tech European chemical industry with its close links to the end consumer markets.

We started preparing for compliance on REACH as far back 2004, assembling a high level Steering Group to assess, evaluate and define the strategic impact of these regulations. Extensive analysis and communication of REACH and the potential impact on both existing and future products was completed within our Business, and an implementation plan agreed to ensure that all substances in our products, intermediates and key raw materials were identified and pre-registered as required by 1 December 2008.

We have successfully completed pre-registration and are able to reassure our customers that all substances within the products supplied by us into Europe that fall under the REACH regulations are pre-registered for use until their required phase-in registration dates.

This ensures the continued ability for us to manufacture and import substances falling under the scope of REACH. We have worked closely with our suppliers and customers worldwide to assist in their understanding and preparation for REACH. Our view is that REACH is complementary to our company commitment to ensure that there is an adequate understanding of the hazards of the chemicals we make and use, and to innovate with technology that improves chemical safety profiles for humans and the environment. We see our current best practice in communicating information on the hazards and safe use of our products as consistent with these objectives under REACH.