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What You Need to Know
The following provides an update of the REACH status of Shell Lubricants companies.
Please advertise this page to relevant collegues, such as REACH focal points, HSE advisors, industrial hygienists or product stewards.
Registration status
Shell Lubricants companies have completed the registration of substances manufactured and/or imported at >1000 tpa. Please also check the product inventory page of this website.
Active pre-registrations
We confirm that Shell Lubricants companies have either pre-registered substances they manufacture or import in Europe (including substances in preparations) that have a later registration deadline of either 31st May 2013 or 31st May 2018 (e.g. grease thickeners).
Other substances imported by Shell Lubricants companies have been covered by an appropriate Only Representative arrangement.
Supplier communication
As Shell Lubricants products are typically complex mixtures comprising substances with different registration deadlines it is not possible to provide a definitive registration date for most products because of the complexity of the supply chain. We can, however, confirm that there are currently no plans to reformulate or discontinue any products as a result of any REACH requirements and furthermore we do not anticipate this situation changing in the foreseeable future. If there are changes in our supply plans as a result of REACH and impacting the products you purchase, you have our assurance that we will inform you at the earliest possible opportunity and work with you to minimize the impact of our decision.
We continue to request assurances from our EU suppliers of purchased components that they remain on schedule to meet the required deadline. At this time, we have no indication that any substances procured by Shell Lubricants companies will not be available beyond 1st December 2010 and accordingly, we do not expect that the products you purchase will be withdrawn for REACH purposes.
Use and Exposure
Please read this section carefully, as you might need to take action.
To determine whether your use(s) of Shell Lubricants products are suitably covered under our REACH activities - please review the guidance and actions we have proposed on our website:
Use and Exposure - What our customers need to do
REACH requires an understanding of how chemical substances are used, specifically, how they are handled throughout their life cycle from manufacture to disposal. For those substances that are hazardous to both human health and environment, a Chemical Safety Assessment, including the development of exposure scenarios, is required for each use to demonstrate that it is safe. This is part of the REACH registration process.
For substances we manufacture (for example base oils, process oils, foots oils, aromatic extracts) we continue to work actively with CONCAWE (the Oil Companies’ European Association for Environment, Health and Safety in Refining and Distribution) who are collating information on product uses for the development of exposure scenarios for use in the Chemical Safety Assessments.
For our blended lubricants (i.e. preparations/mixtures) – we are working in a similar way with the Technical Association of the European Lubricants Industry (ATIEL) and the Technical Committee of Petroleum Additive Manufacturers in Europe (ATC) to map the uses of lubricant products throughout the supply chain for input into the development of exposure scenarios.
Only representative
Shell Lubricants companies have not appointed an Only Representative to cover the imports of our customers.
If you would like to discuss your import of a Shell Lubricants product into Europe, please contact your usual Shell Lubricants representative.
Substances of Very High Concern (SVHC).
Most of the substances in the EChA Candidate List of SVHC for authorisation, available on the ECHA website have been included in our own Shell Lubricants Restricted Substances List for well over 10 years. This means that, during this time, they have been prohibited from use in new formulations developed for Shell Branded Lubricant products, and where they were known to be used in existing formulations, they were high priority for replacement.
As the EChA Candidate List of SVHC for authorisation is frequently updated to include new substances, we have issued a separate “SVHC communication” that will be kept aligned with the latest version of the EChA List .
Please visit the SVHC status section on this website where you can read and download the communication.
Material Safety Data Sheets (MSDS)
Substances
For the substances that Shell Lubricants companies have registered in 2010 – a revised eSDS will be available as soon as possible after the Registration deadline.
If we identify a significant change to the information in risk management or classification based on new hazard information – a revised eSDS will be re-issued without delay.
Mixtures
For the mixtures we place on the market – if we receive any information that causes a significant change to the advice provided on our eSDS – we shall re-issue a revised eSDS without delay. If we do not have any significant new information we will re-issue our eSDS as soon as possible and no later than 1st December 2012 for mixtures comprised of substances registered in 2010.
Further information on Safety Data Sheets (including a guide to the upcoming changes and additional Questions and Answers) will be found soon on our REACH website.
We look forward to working closely with you to ensure REACH compliance of our products. In the meantime, please contact your usual Shell Lubricants representative if you would like to discuss any aspect of REACH in more detail.