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Here is some additional information that may help you understand REACH:
The REACH Directive is aimed at the safe use of chemicals. It replaces numerous EU laws related to chemicals and is complementary to other environmental and safety legislation. This legislation was approved by the European Parliament and its Council and comes into force on June 1, 2008.
One exemption to the Directive which we hope you are aware is the article exemption under REACH. It is our understanding that importers of articles* will not have to pre-register or register chemical substances contained in the article unless said substance (total quantity over 1 metric tonne/year) is intended to be released from the article during normal or reasonably foreseeable conditions of use. Moreover, in the event that the article contains a Substance of Very High Concern*, the importer of the article or their appointed Only Representative would have to notify the European Chemicals Agency as indicated in the REACH regulation.
If you have any questions regarding the above information feel free to contact me directly at the numbers below. Also, additional information regarding REACH is available at the following website: http://ecb.jrc.it/reach//
*As defined by the REACH legislation EC no 1907/2006, Article 3 (1-3)
Substance: means a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability and any impurity deriving from the process used, but excluding any solvent which may be separated with affecting the stability of the substance or changing its composition.
Preparation: means a mixture or solution composed of two or more substances.
Article: Means an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.
Substances of very high concern (SVHC) - Article 57 (a) – (f) means:
(a) Substances meeting the criteria for classification as carcinogenic category 1 or 2 in accordance with Directive 67/548/EEC
(b) Substances meeting the criteria for classification as mutagenic category 1 or 2 in accordance with Directive 67/548/EEC
(c) Substances meeting the criteria for classification as toxic for reproduction category 1 or 2 in accordance with Directive 67/548/EEC
(d) Substances which are persistent, bioaccumulative and toxic in accordance with the criteria set out in Annex III of EC no 1907/2006
(e) Substances which are very persistent and very bioaccumulative in accordance with the criteria set out in Annex III of EC no 1907/2006
(f) Substances – such as those having endocrine disrupting properties or those having persistent, bioaccumlative and toxic properties or very persistent and very bioaccumulative properties, which do not fulfil the criteria of points (d) or (e) – for which there is scientific evidence of probable serious effects to human health or the environment which gives rise to an equilavent level of concern to those of other substances listed in points (a) to (e) and which are identified on a case by case basis in accordance with the procedure s et out in Article 59 of EC 1907/2006
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