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CASE STUDY: Cosmetic company Print

Background: 

                

A small size enterprise, cosmetic company, uses a substance that they feel may have to be registered under REACH.  They decide that they need to investigate a possible substitute for the substance and look to the TESS toolbox and in particular the bioblocks database in the toolbox.

Users:

Legal affairs manager, health and safety (H&S) advisor, R&D manager and staff, production manager, marketing people

Preconditions:

REACH awareness and up-to-date data. Access to the TESS Toolbox. Comprehension of acceptability criteria for their current substance. Comprehension of advantages and disadvantages of the substitution.

Description:

A small-size cosmetic company evaluates the components of their products in the light of REACH. In this evaluation they use the guiding tools created by WP2 (outline of REACH process, REACH work flow) to predict the future of substances not yet registered. H&S advisor identifies an emulsifier, a component of a product from their cosmetic line, to be under suspicion for being persistent and bio-accumulative.  It is produced in a non-EU country and the company is a direct importer of small quantities (~1 tonne/year). The company cannot justify the expense of going through authorisation process and furthermore cannot rely on the producer to do the work for them, since he is not yet obliged to do so. The company can wait and see if it is going to be authorised by someone else, but they decide to progress this themselves.

Business manager proposes several possible solutions.

One of them is a complete stop of the production of the product that has the substance at risk as a component. This option is discounted as the product produces approximately 20% of the company’s operating profits.

A second solution is replacement of the substance. He looks for assistance in the toolbox: he searches the database of substances already available on the market that meet the acceptability criteria. He is aware which criteria from those listed in the toolbox that are the most relevant for the replacement from the company’s point of view, and finds a substance that is similar to the one that needs to be replaced; similarity comprises chemical structure and physical properties that determine the performance of the substance. The literature data that the toolbox refers to has to be carefully assessed in the light of company’s estimated technical and economic possibilities. R&D department is also consulted in this step, to estimate the technical possibility of replacement and functionality of the substituted final product. This evaluation could well involve sourcing some of the substitute product and formulating a final product for performance testing. The conclusion is that changes in the final formulation do not comprise performance in product properties and final use. The costs are slightly higher because of lower availability and higher price of the replacement substance. Production process modification and technical investments are minor. Overall conclusion is that the company will benefit from the change, as the final product is retained, and the substance under suspicion is removed from the final product. The environmental issues are avoided, since the substitute substance has a different metabolism path than the substance it is replacing. Marketing department investigates if the minor changes in product formulation will have a significant impact on product perception by the customers, and conclusions are positive. Once the issues are addressed and the solutions presented to top management, it decides to approve the change in production process and the product is retained.

If the solution among the offered ones does not satisfy the demands in any of the steps (substance properties, performance, technical viability, economic issues), the business manager looks for another substitute in the database of the biobased products. Another reason for the search in this area is that the management decides that it is in the company’s interest to “go green” due to market pressure and image of the company.

Manager performs a search among the existing and possible uses of substances in the database of building blocks from renewable sources. Once the possible substitute is identified, its production costs are estimated: it is currently not on the market and requires further testing and improvement. Literature data provided by the database is carefully studied. Viability of change is studied – are the properties of the novel substance close to the one that has to be replaced? Does it give the desired properties and performance to the product? R&D department is consulted as to the possibility of the change and potential improvements. Production manager evaluates other advantages and disadvantages of the replacement: viability of technological processes in their specific environment, costs of the replacement, marketing benefit. They evaluate if it is viable to produce the substance they need themselves or find a producer that has the necessary equipment and knowledge. R&D and production together advise if the company has the necessary means to perform such a change. If the overall estimation of the technical and economic issues are acceptable then further market research will be required as there will be a slight change in product appearance. A renewable origin of the novel substance is a very strong plus in the final consumer’s evaluation, since public awareness of the issues is already strong and getting constantly stronger. 

Requirements for the Toolbox:

  • Possibility to interact with other users
  • Links to information source on practical matters concerning REACH
  • Process to evaluate REACH resistance, manufactured volumes etc.
  • Links to the REACH IT systems
  • Links to substance databases
  • Outside sources (academic and patent literature data) provided, in the form of external or internal links
  • to www or the toolbox itself
  • Links to other useful advice and support services
  • Possibility to manoeuvre through the databases from different search criteria (e.g. potential or existing use of substance, starting material for production etc.)
Last Updated ( Tuesday, 12 February 2008 )
 
© 2017 REACH Regulation: Registration, Evaluation, Authorization and Restriction of Chemicals: REACH Legislation