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REACH

REACH - Regulation, Evaluation Authorisation and Restriction of Chemicals – is a new EU legislation. The overall objective is to improve the protection of human health and the environment from the risks of chemicals and provide increased transparency whilst maintaining and enhancing competitiveness of the EU chemical industry.

Croda is one of the world’s leading manufacturers of speciality chemicals, surfactants and oleochemicals and our products are used in many downstream applications. We have a strong track record in managing our commitments under our Responsible Care programme and through our focus on sustainable development and welcome the development of an improved and modernised regulatory framework for chemicals within the European Union.

The overall principle and objectives of REACh on chemical policy and the overall intent to make manufacturers, importers and users of chemicals responsible for collecting information, assessing the risk of chemicals and to demonstrate how any risk can be managed are fully supported by Croda.

The final version of REACh was adopted on December 18 2006 with implementation from 1 June 2007. We have adopted the new safety data sheet format for any newly produced safety data sheets and have plans in place to ensure that all existing MSDS are converted to the new format before the deadline of December 2010 agreed by the Member States.

| We have taken action to prepare our business for REACH. Our REACH Readiness Project commenced in 2006 to make sure the actions required for REACH are identified and implemented on time.
| We recognise that information on the REACH status of our products is critical to our customers’ assessment of REACH impact and are willing to share the REACH registration status of products with customers.
| Our product portfolio includes chemicals which will not require registration or evaluation.
| We intend to pre-register* all chemicals manufactured or imported by the Croda Group that are in scope. This is important to ensure that our products continue to benefit from “phase in” status.
| We will comply with the phased registration model but it is too early at this stage to give a commitment that all products will be registered.
| We will be contacting customers to properly understand their uses and ensure that those that can be safely continued are covered in the registration. This will be carried out in line with the phasing of our registrations.
| Our REACH preparation is – by intent and design – not internalised. We believe our approach to proactively inform and work with our customers is vital to maintaining our customers’ confidence in Croda and our products.
| Our professional resources have a long track record in managing regulatory obligations worldwide. These resources will be managing our REACH obligations.
| Our business has played a prominent part in the development of REACH acting as one of the leading advocates in shaping REACH and the workability of the legislation.

Many of the Croda Lubricants products are exempt from REACH registration due to either being listed on Annex IV – chemicals of recognised low concern - of the legislation or being covered by the descriptors on Annex V – naturally occurring unmodified substances - of the legislation.  Products that are in scope of REACh will be pre-registered under the REACh Regulation.

Croda’s intention is to complete the full REACh registration* in line with the tonnage band phase in deadlines. Customers will be contacted closer to the time to discuss uses of their product to be included in the registration dossier.

*This is an expression of Croda's intentions only and is not a representation for legal purposes.

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