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Impacts of REACh, ITAR and other regulations on
Energetic Materials Sustainability
Geneviève Eck, Mohamed El Othmani, Julie Perouel, Delphine Dru, Bruno Nouguez
EURENCO, 1928 route d'Avignon, CS 90109 Sorgues- 84275 VEDENE, France
g.eck@eurenco.com – Phone : +33642117722
1- INTRODUCTION
EURENCO has for many years been producing a complete range of high explosives as well
as the compositions based thereof.
Most of these compositions require the implementation of solvents or various components
such as plasticizers, catalysts, binders or bonding agents. In the last years, the availability of
these components has become more and more critical because of European or US regulations.
Many European companies have to face to these regulation.
Thus EURENCO has identified the chemical components considered as critical in its
production process. Some of them have been or will be banned by REACh (Registration,
Evaluation, Authorisation and Restriction of Chemicals) regulation. The other products are
subject to exportation limitations such as ITAR (International Traffic in Arms Regulations) and
EAR (Export Administration Regulation) or sometimes by producers themselves which are
reluctant to provide products for military applications.
Depending on the component and also the type of regulation, different strategies have been
applied to deal with this new issue:
- Find new suppliers of the same component
- Replace the critical component be another one that is supposed to be chemically and/or
functionally equivalent
Thus the impact of these regulations could be minor as well as of great importance which
means that this can lead to the complete requalification of the composition.
The objective of this paper is to present a summary of the work performed in this area.
2- IDENTIFICATION OF THE CRITICAL COMPOUNDS
2.1- Components impacted by REACh regulation
REACH is a regulation of the European Union, adopted to improve the protection of human
health and the environment from the risks that can be posed by chemicals.
In principle, REACH applies to all chemical substances except polymers; not only those used
in industrial processes but also in our day-to-day lives, for example in cleaning products, paints
as well as in articles such as clothes, furniture and electrical appliances. Therefore, the
regulation has an impact on most companies across the EU.
