The European Union (EU) has implemented a new chemical regulatory policy called REACH (Registration, Evaluation, Authorization and Restriction of Chemicals). The European Chemical Agency (ECHA) is the official registrar for REACH and additional information can be found on its website at www.echa.europa.eu. The purpose of this communication is to respond to requests regarding REACH compliance of products purchased from PRC.
ECHA Guidance on Requirements for Substances in Articles (May 2008) indicates the following:
2.1 Registration according to Article 7(1) (and 7(5))
A registration (Article 7.1) of substances in articles is obligatory for an article producer or importer only if the following conditions are met:
The substances are intended to be released from the produced or imported article(s) during normal and reasonable foreseeable conditions of use
The total amount of the substance present in the articles with intended releases produced and/or imported by that actor exceeds 1 ton per year per producer or importer.
REACH registration duties DO NOT APPLY to manufactured products which are referred to as 'completed articles'. Substances (chemicals) are subject to REACH registration, NOT products.
PRC does not manufacture any products that contain substances intended to be released nor produce any basic chemical substances. We have never shipped chemical substances in excess of 1 metric ton to the EU.
As far as the SVHC list is concerned we have yet to be notified by any raw material supplier to the presence of any substances of very high concern from the current SVHC List. According to Article 7(7) Suppliers have a legal obligation to notify downstream users to the presence of any SVHCs within six months of the substance being added to the Candidate List. We are in the process of verifying compliance with individual suppliers of raw materials that are present in our finished articles as of the latest addendum. In the mean time we have made a PDF certification available via the web (directly below) or you can request a hard copy be sent via our RFQ form found at the very top of every page that covers all SVHC's listed prior to the latest addendum.
If you require a certificate of compliance you may download the relevant PDF by following this link:
R.E.A.C.H. Certificate of Compliance (PDF)