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what is the impact to ExxonMobil?
While REACH entered into force 1 June 2007, the first significant requirement for most businesses was the pre-registration of substances, which was open from June 1st until Dec 1st 2008. Pre-registrants will benefit from a phasing scheme for registering existing substances (2010, 2013 or 2018). By pre-registering, companies will be permitted to continue manufacturing and/or importing the substance up and until the registration deadline for their respective volume.
It is estimated that of the approximately 30,000 substances expected to be registered industry wide, ExxonMobil will register up to 1,000 substances in the 11 years after the legislation came into force. While the new regulation creates a large effort, ExxonMobil has the resources, the commitment and much of the data that is required under REACH. We are working actively with industry associations such as CEFIC and CONCAWE to develop and deploy standard tools and processes which will allow us to implement the requirements for REACH with minimal disruption to ExxonMobil or our customers’ and suppliers’ operations.
The effort to develop the documentation necessary for REACH compliance has started to ramp up and will continue for several years due to the fact that the full impact of REACH legislation will roll out over an 11-year period. It should be noted that the bulk of ExxonMobil's effort will be focused on the 2008 to 2012 time period since most of ExxonMobil’s substances are required to be registered in 2010.
Additionally, ExxonMobil has a strong commitment to Product Stewardship through our Operations Integrity Management System. The REACH regulation is consistent with our existing philosophy of using science to understand the risks associated with the products we sell and then communicating these to our customers and supply chain partners.
It is possible that some substances currently on the market may not be registered for cost reasons. This will occur at all steps along the supply chain. ExxonMobil will be working closely with its suppliers and customers to minimize any disruption to our operations and to their operations as a result of such potential product withdrawals or reformulations.
