Frequently Asked Questions
Our database of Frequently Asked Questions (FAQs) contains questions and answers on issues, which are of general interest for our customers or issues raised most frequently by our customers. The database is updated regularly.
How is Castrol Industrial managing the implementation of REACH, and who do we contact for further information?
Compliance with REACH has a very high priority for us. A central project team was established several years ago to oversee the process. Your main point of contact for our Business is identified under REACH LOCAL CONTACTS.Will all the products supplied by Castrol Industrial continue to be available?
We have pre-registered all the substances that we are legally obliged to (manufactured or imported). As a blender of lubricants we purchase a number of raw materials from third party suppliers. To obtain assurance of supply we have contacted all our raw material suppliers to understand their intentions regarding pre-registration. We are not expecting disruption to lubricant product supply as a result of the REACH legislation.As there is no legal obligation to provide pre-registration numbers we do not intend to supply this information.
Which substances contained in your products may be subject to Authorisation?
Screening of the current Risk Phrases of our component substances is currently being carried out to identify chemicals that are potentially at risk.Please comment on the steps you are taking to ensure that these substances will be Authorised or replaced, as appropriate.
We will work with our suppliers and relevant trade associations where Authorisation of substances is required. This is a new process and we, in common with our industry peers, are monitoring how it is working in practice.Which customer uses will you and your suppliers support in registration dossiers?
We will support the use(s) of our products as indicated in their Technical Data Sheets. If you consider your use to be ‘novel’ or fall outside these uses, then we will need to understand the implications of covering such uses. Inclusion of additional uses in registrations is likely to require supporting information from our customers.How will you communicate with customers about which uses will be covered in registrations?
A working group from Technical Association of the European Lubricants Industry (ATIEL) and the Technical Committee of Petroleum Additive Manufacturers in Europe (ATC) has been reviewing the typical uses of all lubricant products.The use descriptor information on the ATIEL website covers all the standard uses of the lubricants listed. Therefore it is expected that customers who use products for their intended purpose will not need to give us any additional information. We have sent out this information to all our customers.
All necessary information will be incorporated into our Safety Data Sheets as required. Where required, we will add exposure scenarios to our SDSs for the described product use to communicate the required information to our customers.
Do you expect to request use and exposure information from your customers?
We have already identified a number of generic uses for lubricants and are currently working to develop exposure scenarios for them. Supporting information for these exposure scenarios will be requested, where necessary, from trade associations and customers. Where possible we will use industry standardised IT tools for such communications – these tools are currently under development.What are the implications if a customer imports into the EU an article containing your lubricant?
The answer to this question will depend on whether the substances in the article are intended to be released during any stage of the product life-cycle (other than the waste stage). If there is intended release there will be an obligation on the importer to register all components exceeding 1 tonne/annum/legal entity.If there is no intended release the component will not fall under the REACH requirement for registration. This is the case for any corrosion protection film (mixture of components) applied to an article. In this case the film is part of this article and can be imported into the EU.
Do your products contain Substances of Very High Concern from the Candidate List for Authorisation ?
ECHA is frequently up-dating the candidate list of substances for Authorisation. We are routinely monitoring additions to the Registry of Intentions and the Candidate List of SVHCs, identifying products (if any) that contain these substances, and making any required changes to SDSs.For a product purchased I have noticed that not all the CAS numbers in Section 3 of the Safety Data Sheet appear on the ECHA listing of active SIEFs with a Lead Registrant assigned.
SHOULD I BE CONCERNED THAT THE PRODUCT I PURCHASE WILL COMLY WITH THE REACH REQUIREMENTS AND WILL STILL BE AVAILABLE?There are a number of legitimate reasons why some substances identified in Section 3 of a Safety Data Sheet are not listed on ECHA's list of active SIEFs.
These include:
1. The CAS number may relate to a substance which does not have a registration deadline yet in which case the SIEF may not yet be active.
2. There is no legal requirement for a Lead Registrant to advise ECHA of their status and so the SIEF maybe active but ECHA have not been advised.
3. As a result of REACH activities there have been instances of CAS number re-alignment, e.g. SIEFs splitting or merging resulting in new CAS number identification. If this is the case it will become clear when an updated Safety Data Sheet is issued by your supplier.
4. In the past some suppliers have used generic CAS/EC numbers together with generic chemical descriptions for hazardous substances listed on the Safety Data Sheet to disguise the more precise chemical identifiers that will be used for REACH registrations.
1. The CAS number may relate to a substance which does not have a registration deadline yet in which case the SIEF may not yet be active.
2. There is no legal requirement for a Lead Registrant to advise ECHA of their status and so the SIEF maybe active but ECHA have not been advised.
3. As a result of REACH activities there have been instances of CAS number re-alignment, e.g. SIEFs splitting or merging resulting in new CAS number identification. If this is the case it will become clear when an updated Safety Data Sheet is issued by your supplier.
4. In the past some suppliers have used generic CAS/EC numbers together with generic chemical descriptions for hazardous substances listed on the Safety Data Sheet to disguise the more precise chemical identifiers that will be used for REACH registrations.
Can you provide a Pre-registration or a Registration number for your products?
Pre-registration and Registration numbers are allocated to individual substances and not formulated products. Castrol Industrial is principally a formulator of lubricants and related products and purchases its raw materials from suppliers. It is the responsibility of these suppliers to pre-register and subsequently register their substances. For this reason we will not have access to the pre-registration numbers.
Castrol Industrial has pre-registered the small number of substances that it manufactures or imports.
Castrol has successfully sub-mitted all its required REACH registrations ahead of the legal deadline to the European Chemical Agency (ECHA).
Following registration of substances at their required times (including the future June 2013 and June 2018 deadlines) the substance registration number will be given in the Extended Safety Data Sheet from the supplier. The Safety Data Sheet of the formulated lubricant product will also contain substance registration numbers where a substance is required to be identified in section 3 of the Material Safety Data Sheet under the requirements of REACH. (As defined in REACH Annex II, sections 3.2 and 3.3)
Following registration of substances at their required times (including the future June 2013 and June 2018 deadlines) the substance registration number will be given in the Extended Safety Data Sheet from the supplier. The Safety Data Sheet of the formulated lubricant product will also contain substance registration numbers where a substance is required to be identified in section 3 of the Material Safety Data Sheet under the requirements of REACH. (As defined in REACH Annex II, sections 3.2 and 3.3)
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