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REACH is the new EU legislative provisions of REACH concerning chemicals and their safe use. These provisions relate to the registration, evaluation, authorisation and restriction of chemical substances. Depending on the role taken in the supply chain, different duties will apply.Under REACH, chemical substances have to be registered. However, finished articles do not.
- As a supplier of articles such as electronic components, electronic equipment and accessories, we are not required to register such articles under REACH.
- As an importer of products, we are required to register substances contained in products where a minimum of 1 tonne per year per manufacturer is contained and, during normal or reasonably foreseeable conditions of use, is released.
- We have a duty to inform the Agency if “substances of very high concern” (for example, substances which fulfil the criteria of Article 57) are contained in a concentration greater than 0.1% weight by weight, and total more that 1 tonne per year.
For articles imported from non-EU countries, the information that has to be provided depends on the type of article. Under Article 7.1, REACH regulates articles from which substances are intentionally released. Articles which contain substances with particularly dangerous properties are regulated under Article 7.2. Article 33 regulates the duty to communicate information about substances contained in articles.
As a supplier of substances, preparations and articles, we will observe our duty to communicate information under Article 33. As an importer of articles (for example, electronic components, power supplies, fans) we will check whether our articles contain “substances of very high concern” (SVHC). We will not import into the EU articles which, in their normal use, intentionally release substances.
ECHA has published the Candidate List of Substances of Very High Concern (SVHC) which, from 1 June 2009, will form the basis for inclusion in Annex XIV of the REACH provisions. With the publication of this list, all those involved in the supply chain are subject to the obligation to communicate information under Article 33 of REACH. We have informed our suppliers about the publication through ECHA of the list of candidate substances, and have pointed out the resultant obligation to communicate information within the supply chain. The lawmakers have not yet precisely defined the “reasonable period of time” to comply with the duty to communicate information. As soon as this “reasonable period of time” is determined, we will inform you of this on this webpage. Our objective is to comply with the duty to communicate information as early as possible within the “reasonable period of time.
Please note: the above declaration was created and issued on the basis of currently applicable laws and regulations and in accordance with the best of our knowledge and the present state of information.
(as at 01 November 2008)
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