Daniel Marr , commercial director at Airedale Group , offers advice to chemical manufacturers on what to be aware of before entering a contract with third parties
A regulatory reality check for contract manufacturers
Daniel Marr , commercial director at Airedale Group , offers advice to chemical manufacturers on what to be aware of before entering a contract with third parties
Entering into a contract manufacturing agreement can be an overwhelming prospect . Companies looking for a partner need to find one that has the facilities needed to test and manufacture their products . They should also look for one with the in-house expertise and the ability to help tweak formulations to create exactly the right solution .
Airedale Group has found that the most productive way to run these partnerships is for each party to find out and understand what they are responsible for in the process and which roles they will play in meeting any regulatory requirements and associated costs as the project progresses . For this reason , we provide dedicated account managers to our contract . They ensure that communication is constant and that we are always available to speak with clients and complete the project on budget and on time .
Communication is also key to understanding where a customer ’ s products will be placed on the market . If the country of manufacture is different from where the product will eventually be sold , there may be further regulatory requirements that need to be met . In the case of REACH , this may be via an appointed representative .
Contract manufacturers may also need to consider the impact of additional products present on site . The arrival of hazardous materials or extra tonnage could have an impact on regulations and rules relating to hazardous substance consent .
The REACH effect
We are seeing new REACH regulations appear around the world with additions including KDIKK in Turkey , K-REACH in South Korea , and UK REACH in post-Brexit Great Britain ( not including Northern Ireland , which remains in the EU Single Market ).
As a British company , Airedale needs to comply with UK REACH for all the substances it manufactures and imports of > 1 tonne per year . Where new substances are manufactured or imported and a registration is required , this can lead to an upfront cost and a delay in the process of bringing products to market . There are also many other productspecific regulations to be aware of , including those for detergents , cosmetics and , of course , the Biocidal Products Regulation .
Contract manufacturing post-Brexit
Life in the chemical manufacture , supply and distribution world became even more complicated in the wake of Brexit , which continues to have reverberations today in our industry as well as many others .
Blending facilities at Airedale Group
Since leaving the EU , the UK no longer benefits from the freedom of movement which it previously enjoyed . Customs checks apply to goods passing to and from the EU and the management of the paperwork needed to transport them can lead to delays , which is something contract manufacturers need to be aware of and factor in when considering the timescale of a project .
Regulatory divergence continues to be a feature of the post-Brexit chemical industry . For example , the UK and EU both differ in their approach to the control of explosive precursors . The EU brought in its regulation shortly after Brexit , whereas the UK , which updated its existing Poisons & Explosive Precursor regulation in October 2023 , took steps to include additional substances beyond those regulated in the EU .
UK manufacturers are now also required to undertake their EU REACH registrations via an appointed EU Only Representative .
42 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981