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.
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
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.
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.
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?).
excerpt from the HSE / REACH government agent
promised a brief summary of our conversation yesterday:
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).
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
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
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.”
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.
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.”
confirm we are 100% legal to sell to the trade / industrial. We cannot sell the
USA dip to retail customers.
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.
from the HSE / REACH agent
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.
look forward to your response, in the meantime if we can be of further
assistance, please do not hesitate to contact us.”
further question feel free to call us on 01799 541928
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.
plastidip.co.uk products contains xylene AND naphtha and are the EU / UK
Health and Safety Executive
Registration, Evaluation, Authorisation & restriction of CHemicals
checked with the HSE agent he was ok for me to add this to the website, this
was his reply.
can only comment on the parts of the text below that relate to the factual
accuracy of your statements concerning REACH.
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.
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