NickAlchemy Ltd is a metals company that produces specialist nickel- aluminium alloys. These alloys can also contain other "minor metals" (e.g. niobium, tantalum) in various quantities. NickAlchemy has 20 standard alloys in their product range that are each produced at around 10-200 tonnes per year. It also has a range of over 30 custom alloys that are produced on demand in volumes of between 1 and 50 tonnes per year.
NickAlchemy's customers are looking for reassurance that they will continue to be able to do business with them and have been asking if the products they get from NickAlchemy are going to be registered under REACH. The managing director, Ian Westcons, did some research into REACH (on the UK Competent Authorities’ website) and found that it requires manufacturers of substances to submit a registration for their products. Initially, he was rather worried that all 50 or so alloys would need to be registered. Rather than trawl through the entire REACH text, he used his computer to do a search for mention of the word "alloy" and discovers that alloys are being treated as "special preparations".
This means that although each alloy will often have unique properties, they are being treated as a formulation of the elements used to produce them. As with other formulations it is the substances/ingredients that make up the formulation/alloy that are registered separately. For NickAlchemy's products this would be the nickel, aluminium and the other metals.
Through his research Ian also found that the position of his company in a supply chain will affect his responsibilities under REACH. He looked at his supply situation in more detail and found that:
This means that NickAlchemy has two responsibilities under REACH, one as a downstream user and another as a registrant.
For the aluminium and the minor metals NickAlchemy will be a downstream user. For these substances Ian informs his suppliers of his uses and asks his customers to tell him about their uses, so that he can pass this information up the supply chain. The suppliers can use this information in the registration packages they (or their suppliers) need to make.
For the Nickel, the company is an importer and as such is required to make a registration. Ian contacted his trade association and found that a group has already been formed for the registration of nickel. He decided to join this group. His next step is to pre-register as an importer of nickel. The pre-registration will be made to the European Chemicals Agency between 1 June 2008 and 30 November 2008 (inclusive).
By pre-registering, NickAlchemy will be able to take advantage of the phase-in provisions of REACH and can delay making a registration until the appropriate deadline. He is now able to reassure his customers that he has taken the necessary steps to ensure he is able to continue supply in the near future.