ILMA Announces REACH Consortium for Members

ALEXANDRIA, VA (June 17, 2008) — The ILMA has formed a REACH consortium to assist members in their compliance with the European Union's (EU) new chemicals regulation. The action was taken in response to member concerns about the high cost of "go-it-alone" strategies for REACH compliance.

Following review of several proposals submitted in a formal RFP process, the Association has approved the proposal by the Redstone Group to assist ILMA members — Manufacturing, Supplier and Marketing — address cost-effectively various aspects of their REACH activities.

Pre-registration, the first phase under REACH, began on June 1 and continues through November 30, 2008. Pre-registration involves the assembly of key information on each chemical substance placed in the EU markets, and ILMA has encouraged Members to pre-register for a number of reasons, including the ability to continue do business in the EU after January 2009.

The costs of the consortium will be variable, depending on the number of participants. "There is no cost to pre-register; however, pre-registration is not without costs," ILMA General Counsel Jeff Leiter noted. Based on assumptions made by ILMA, the Redstone Group estimated the costs at:

The costs will be lower on a per-member basis if more than 20 companies decide to participate in the consortium.

The consortium, which will be operated separately from ILMA, will function, utilizing a web-based system, to collect the information necessary for an ILMA Member to understand its obligations and develop strategies in a timeframe sufficient to complete all pre-registration activities by November 30, 2008. Because of the need to move quickly in getting the consortium up and running, ILMA is looking for a non-binding commitment by members to participate by July 1, 2008.

A key benefit of the consortium is to get over the hurdle of confidentiality concerns with product formulations and customer names. Accordingly, a key element of the consortium will be mechanisms to protect confidentiality of suppliers and formulators' formulations and customers. Each participant will load its unique information into the web-based system; however, they will not have access to data provided by other participants. The system output will consist of reports indicating substance exports identified in the applicable tonnage bands.

Leiter said, "The system Redstone is putting in place for ILMA Members will be suited to the needs of both Manufacturing and Supplier Members. More importantly, it will facilitate communication between Manufacturing and Supplier Members, as well as their customers, as everyone tries to coordinate their REACH pre-registration activities."

"REACH is a complex regulation, and ILMA has been working hard to help its members understand the implications of this regulation, develop and execute sound compliance strategies, because failure may result in their inability to sell lubricants in the EU markets," said ILMA Executive Director Celeste Powers. "The Association is very pleased to have the Redstone Group and its affiliates available to ILMA Members, and I encourage all Members who are affected by REACH to consider joining the consortium."

Because the time to prepare for pre-registration is a tight window, ILMA members interested in participating were advised to contact either Jeff Leiter (jll@leitercramer.com) or Adam Cramer (abc@leitercramer.com) as quickly as possible. Interested members then will be put in touch with the Redstone Group.

For those ILMA Members who do not want to take advantage of the consortium, the Redstone Group also is in a position to assist Members individually with their REACH compliance activities. Further, ILMA can provide members with the names of other firms that can serve as "Only Representatives" under the REACH program.

The Independent Lubricant Manufacturers Association (ILMA) was founded in 1948. ILMA's 292 members include independent lubricant companies that produce more than 25% of all lubricants and 80% or more of the metalworking fluids and other specialty industrial lubricants sold in the U.S., and key suppliers of raw materials and services to independent lubricant manufacturers.