- June 2008 to November 2010 for high-volume or high-hazard chemicals.
- November 2010 to June 2013 for moderate-volume chemicals. Kraska said this is the timeframe most likely to start impacting lubricant additives.
- June 2013 to June 2018 (possibly 2020) for lowest-volume chemicals.
Companies can make doing business in Europe easier if they are able to do some toll blending there, Kraska said. Thats a good idea, as it takes a lot of your REACH responsibilities away, he said. European companies will be REACH-compliant or they will be out of business. However, he says there are some chemicals where suppliers may not be up to the REACH challenge, including dyes, odor masks and sulfonates.
Kraska explained there is an exemption if a company exports less than one ton of a chemical into Europe per year. This has pitfalls, he said. It limits your business forever, he said. Second of all, you may find out a little too late that your customers are exporting a lot more product than you are. And your automotive customers are not likely to accept the explanation your product is REACH-compliant because you dont export more than a ton.