Answers to questions at TireTech Forum 2007

Q: Anti Aging agent which is added into tire will eliminate automatically during the usage. The question is whether the tire needs to be registered because tire uses lots of anti aging chemicals.

A: Remember REACH is not about final product. It’s always about the substances that made final product. Tire manufacturing is a very complex process. Manufacturer, importer and distributer of tire need to evaluate each responsibility in terms of chemicals usage and toxicology to determine the registration process.

Q: Raw material suppliers provide the certification, but derivatives were produced during manufacturing process. The question is whether the tire manufacturers need to find these derivatives and register it.

A: If the derivates end in tire to become part of the tire component, the derivates need to be registered.

Q: What is REACH checking process? For example, whether and how they do the sample checking? How or where to know the process for register the product?

A: REACH checking process depends on the chemical usage and level of toxicology. Actually the whole Evaluation process under REACH is one of ECHA main duties to make sure the chemicals are registered correctly and if any further tests are needed. That’s why it is so important that everybody follow REACH guideline.

Q: Where to find Clarification of chemicals?

A: Manufacturer, importer, and distributer should at least have some chemical clarifications in terms of safety hazard and toxicology. After chemicals being pre-registered, ECHA will compile a pre-registered list of chemicals and a confidential list of companies that share the same chemicals. Then those companies must form a SIEF forum to share the information between members.

Q: Who is responsible for registering the mixed compound?

A: This is a very broad question and needs more definition on mixed compound. Again, the whole supply chain has to work together as a team to figure out whose responsibility and in what area.