Insightful article by Adrian Nixon, an advisory board member of the National Graphene Association.
Graphene, Just Out of REACH
If graphene were a person it would still be growing up. It is a teenager by some measures and a baby by others. Many of the graphene companies in the market are rightly focused on the technology of making graphene. However, technology is only part of the commercial success criteria.
In this evolving market, few suppliers seem to be thinking about the supply chain for this new material. REACH is one of the blind spots. If your company makes or sells graphene you need to know about this.
To find out more I sought out Bernhard Münzing.
Bernhard is the Sales Director for one of the largest graphene manufacturers in the world – The Sixth Element (Changzhou) Material Technology Co, Ltd. He is also a highly experienced industrial chemist and the chair of the REACH consortium that is focussed on graphene. I managed to get some of his time for an interview and asked him some questions…
What is REACH?
REACH refers to the Registration, Evaluation, Authorisation, and Restriction of Chemicals in Europe. It is a key regulation that covers the European market.
REACH in Europe entered into force in 2007 and applies to all chemicals manufactured or sold in Europe in the following quantities:
In 2010 the regulation applied to any material over 1000 tonnes.
In 2013 this limit was reduced to 100 tonnes
On the 31st of May 2018, this will be reduced further to cover all materials above 1 t.
Chemical products can be manufactured or sold in quantities less than one tonne without complying with the regulations, however, this can be expected to reduce further with time.
Why does it matter?
REACH is the strictest law to date regulating chemical substances and will affect industries throughout the world.
When REACH is fully in force, it will require all companies manufacturing or importing chemical substances into the European Union in quantities of one tonne or more per year to register these substances with a new European Chemicals Agency (ECHA) in Helsinki, Finland.
In essence, you have to have your graphene product covered by this regulation before you have a commercial product. European customers are unlikely to buy large quantities from you unless you can demonstrate compliance with REACH.
Does this affect my company even if I am not in Europe?
Yes. Similar regulations are already being developed in Korea, Turkey, and China; other countries are following and developing similar regulations to REACH.
Also, large multinational companies operate globally and tend to harmonize labeling and regulatory compliance to minimize duplication. By complying with REACH in Europe they will cascade the requirements throughout their organisations.
Graphene is made from graphite; can I just use the graphite REACH registrations to cover graphene?
No. Graphene is considered a separate substance from graphite. The International Standards Organisation (ISO) definition of (few layered) graphene is equal or less than ten layers. For the purpose of registering graphene the substance definitions are being designed to cover a thickness of up 300 nm, beyond that the material can be considered to be graphite.
So what does this all mean for me?
Consortia members are developing the registration dossiers that will cover:
Graphene Oxide (GO)
Reduced Graphene Oxide (rGO)
The REACH registration dossiers for graphene for a tonnage band of up to 10 tonnes per year per registrant are being finalized and will be in place on the 31st May 2018.
If you are part of the consortium there will be no additional charge for getting access to the registrations dossiers to have your graphene products registered under REACH. All costs occurred during the process of establishing the joint registration dossiers will be shared between the consortia members.
If you are not part of the consortium then you will have no influence on the registration strategy, the way that lab work and studies, which is necessary, is contracted, and on any other costs which may occur during the process to establish the joint registrations dossiers. You will also not be co-owner of the studies the consortia has done.
If you want to access the European market with a graphene product that is REACH compliant then you will have to purchase a letter of access to the registration dossier that will enable you to complete the registration of your graphene product. The costs of the letter of access will cover the dossier costs mentioned above plus a premium to cover partly unforeseen actions from ECHA.
In summary, if you play a game where the rules change and you take no notice, then you become a lesser player. Graphene may be an immature technology but the market is growing up fast and graphene suppliers need to recognize this and adapt.
Where can I find more information about this?
If you have general questions about Graphene and REACH you may contact Bernhard Münzing. If you would like to join the consortia, then please direct all inquiries to:
Consortia Management GmbH | Herrnsheimer Hauptstr. 1b | 67550 Worms | Germany
tel: +49 6241 95480 12 | fax: +49 6241 95480 26 | www.consortia-management.com
The contact person is either Doris Peters or Dr. Dieter Drohmann
We should also mention, that registration will continue if companies exceed the 10 tonnes sales or manufacturing level per year. Registration requirements then increase which will mean that a lot of studies need to be done. The highest registration level with the highest requirements is the registration for sales or manufacturing of more than 1000 tonnes per year.