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The UK home of Peelable Paint
REACH

The reason for this page is to clear up a few misunderstandings being put out by plastidip.co.uk. We had a few calls from plasstidip.co.uk stating 'we are going to shut you down'. Almost exactly the same time HSE / REACH contacted me, informing me that they had been ‘contacted about products we sell containing toluene’. Make your own decision about their business strategy.


In brief

Genuine USA plastidip contains toluene. General public are not allowed to buy this, if you are trade and / or make money from plastidip you are 100% legally allowed to buy. The substitute is what PDUK sell. The USA factory subsitute the toluene for xylene. Making it is fully legal to sell to retail and trade then. Much the same as anyone can buy water based paint for cars, but only trade can buy 2k (2 pack).

My thoughts on this - the factory (Performix in USA) now have to make 2 versions, a USA one and an EU one to comply with EU laws. I find the genuine USA and original one with toluene MUCH better. Surely if the factory believed that the USA and EU versions were the same they would not go to all the expense of creating 2 versions? They would just create and sell the one version as it would be cheaper for them? But I would guess they agree and that is why they continue to make the 2 versions, the better USA one and the not so good EU one. But you need to make your own decision on that. Again, back to normal paint analogy, you can use cellulose, but you can use 2 pack for a MUCH better finish.


In Full

Firstly. The issues with USA plastidip is because of the Toluene content. The factory make it and designed it this way, the thinners contain it because it is the way it is intended. To make it UK / EU compliant they have to substitute the Toluene for Xylene. Now as I am sure you are aware once you design something you design it to be the best it is, so once you start randomly changing properties you automatically lose quality. This is what has happened to plastidip, the UK/EU stuff just is not as good as the proper USA dip. This is not hearsay, I have many, many customers who agree having tried both. If simply changing to xylene from toluene was as good, would the factory not just do it? Why go to trouble of making two versions? The answer is simple, they need to placate the EU troublemakers and red tape makers, and sell an alterior product to make it PASS and keep the EU chiefs happy. Of course, all of this is my own assumption, you need to make your own decision on this.

Secondly. The next component REACH do not like is naphtha. Naphtha is generally ok, but it contains a chemical called benzene. As long as this is below 0.1% volume then the chemical is ok for use in the UK / EU. The naphtha we & performix use is less than 0.1% benzene. The EU deem more than 0.1% volume of benzene in a product as harmful. Fuel you put in your car contains MORE than 0.1% benzene. The government make a lot of money from fuel, fuel is exempt from this ruling. Strange eh....

So what do plastidip.co.uk have to gain by calling up customers and telling them that if they do not buy from them they are illegal and will get a massive fine? Well, they are simply trying to control the market and create a monopoly. Their backup for this they tell me, is that they have spent thousands becoming REACH compliant. Well in fact, everyone is automatically REACH compliant until they sell chemicals that are not. REACH do not award out compliance ‘badges’. Being 100% REACH compliant means the chemicals you sell are legally allowed to be sold to trade, industrial and retail. The restrictions on the toluene market mean that it is only allowed to be sold to trade and industrial. So, providing we only sell to trade or industrial we are ALL still 100% REACH compliant. If you dip cars, have a business that uses it, makes a living or earns money from it, you are 100% allowed to purchase or use the USA plastidip. REACH / HSE DO NOT fine anyone. They cannot (as told to me by the HSE agent). However they will look at the facts and if you are deliberately breaking the rules they can take you to court. So plastidip.co.uk are completely lying to you (maybe this is what they have been told though?).


An excerpt from the HSE / REACH government agent


"Alan

As promised a brief summary of our conversation yesterday:

I noted the restrictions of relevance here

Toluene - a specific restriction on the substance such that it cannot be supplied in products made available to the general public as per Restriction 48 of Annex XVII of REACH

Restrictions 28, 29 and 30 which preclude the supply of products to the Public if they contain certain substances (CMRs).

I noted that should you wish to sell a product that is restricted for supply to trade only customers then you website must include a "process” that allows you to ensure (as far as you are reasonably able) that you do not supply to the Public.

If you decide to remove all those substances from your products that are restricted you can carry on your supply as normal. You noted that you intend to replace the Toluene with Xylene. We also discussed the solvent naphtha. I have now had chance to consider this more fully and my view is as follows:

Within the CLP Regulation (Classification, Labelling and Packaging Regulation) there is list of substances with agreed "harmonised classifications”, Solvent Naphtha is one of these, you can find this entry in the full text of CLP by searching the index number quoted on the SDS (649-356-00-4), this appears at page 1289 you will see that this substance carries a classification as a Carcinogen and a Mutagen. The last column contains a "note P”, this means (as detailed on page 467) that if the benzene content of the substance is <0.1% then the substance itself does not have to carry these classifications. The SDS for the substance you use does indeed state this and therefore this classification can be removed and therefore restrictions 28 and 29 do not apply to the solvent Naphtha of products containing it. I should note that because solvent naphtha can be produced in many different ways you will need to check this should you use a different supplier.”

"In summary therefore, if you intend to replace the Toluene in your products with Xylene you can sell such products containing these substances (Xylene and Solvent Naphtha) to the general public.

With respect to the "replacement” product, I note that the "VM&P Naphtha” is also a solvent naphtha stream and therefore the same considerations with respect to the Benzene levels apply, I cannot see from the SDS any reference to the Benzene content so I cannot say, with the information available to me, that this is an acceptable replacement for sale to the public. This particular stream can be found under Index number 649-267-00-0 in the above document.”

So to confirm we are 100% legal to sell to the trade / industrial. We cannot sell the USA dip to retail customers.

We are working on getting a replacement that the retail customers can use, we have finally found one after two years of searching. It is better than plastidip in many ways also, so we will slowly be moving over to this anyway. It will just take time. It is REACH compliant, as in, it doesn’t contain anything they list as a no no, so it will be fully available to anyone.


Finally from the HSE / REACH agent


"Finally we spoke about other company’s making comments about your compliant status. As I noted there is no such thing as a "REACH compliant logo” that we (other any other organisation) gives out. Companies can place this on their website if they believe themselves to be complaint, but there is no guarantee that they are. Hopefully our email exchange and telephone conversation has given you enough information to be able to comment on any accusations that your competitors might make. You can of course always pass these onto ourselves, equally you are within your rights to make a formal complaint about any company you believe to be non-compliant.

I look forward to your response, in the meantime if we can be of further assistance, please do not hesitate to contact us.”

Any further question feel free to call us on 01799 541928

Remember, it is because of these rules and plastidip.co.uk trying to control the market and force up prices that have forced us into this scenario. So if you are trade and make a living and can qualify, see the ‘trade account’ page. We have to show and prove we are confirming you are trade by law. Once that is completed we are all 100% legal.


ALL plastidip.co.uk products contains xylene AND naphtha and are the EU / UK version.

HSE = Health and Safety Executive

REACH = Registration, Evaluation, Authorisation & restriction of CHemicals


I then checked with the HSE agent he was ok for me to add this to the website, this was his reply.


Alan

I can only comment on the parts of the text below that relate to the factual accuracy of your statements concerning REACH.

Just for totally clarity of the text. Firstly Toluene is allowed to be used and supplied in the UK (and across the EU), it is the supply to the general public that is restricted, professional operators can purchase and use products containing it. The same applies to Naphtha, Naphtha containing less than <0.1% benzene can be supplied for Professional and Public use, only if it contains >0.1% Benzene can it not be supplied to the public – in this case however it can still be supplied to the professionals.
On the basis that you have made a business decision to supply to trade only I consider this issue closed.


Regards

XXXX


XXXX XXXXX | HM Inspector of Health and Safety | CRD Compliance Branch | Health & Safety Executive
Chemicals Regulation Directorate, 4NG Redgrave Court,
Merton Road, Bootle, Merseyside, L20 7HS.



So as we are selling the NON EU REACH compliant to the trade, we are fully REACH compliant again. You can be safe in the knowledge you are 100% legal using USA plastidip