Protection of Know-how

The registration of a substance is always linked to one or more applications. This means it is only allowed to use the substance for the application for which the substance has been registered. This means that we have to consider the exposition of human being and environment which, of course, depends on the application of a substance. It is a difference whether a substance is used in a closed industrial equipment or whether it is available for everybody for example in a shower gel.

The producer must, of course, be aware of the application when registering the substance. But this simultaneously means that the customer informs him of the application of the substance in question. This can entail problems. A considerable part of the know-how of the lubricant producer is the fact that raw materials of other sectors are used. The members of our purchase department for example often speak with representatives of the plastics industry who are not aware of the exact application of their "plastic raw materials". Other raw materials come from the areas colours and paints, adhesives, rubber, etc.

Here the REACH principle of increased transparency within the supply chain unfortunately leads to the fact that know-how is endangered. Nobody is willing to give sensitive product information to a third party. And possibly this third party will talk to our competitors since these are supplied as well. The "exposition and application categories" suggested by the VCI and BDI could be an advantage in this respect. Instead of disclosing each individual application with its characteristic possibilities of exposition several similar applications are combined in one bigger category. The supplier of the raw material thus does not know the exact application. However: In our opinion an element of risk remains.