REACh – Enthone Europe Customer Information 2008
Dear Sir or Madam,
With respect to REACh inquiries, Enthone would like to provide you with the
information currently available.
Pre-Registration/Registration:
As a producer of preparations for surface technology, we are considered to
be a downstream user – with certain exceptions – according to
the REACh Regulation.
Our task mainly consists of
- asking our suppliers about (pre-)registration regarding supplied chemicals,
and informing them of our fields of application and the exposure scenarios,
as well as
- co-ordinating with our customers’ fields of application, sending
them new safety data sheets when relevant for safety and informing them on
time of future supply availability.
We are confident about the future supply availability, however, we do not
have assurance from all our suppliers yet, as the pre-registration deadline
only ends December 1st, 2008. Of course, we will take every opportunity
to keep the substances available for our electroplating applications and will
positively influence the decisions of the major chemical companies in the interests
of our branch of industry. We are also working on an industry-wide standardization
of the application descriptions. To this day, none of the products supplied
by Enthone seem to be affected in future supply availability by REACh.
Evidence of Pre-Registration:
While the number of customer requests for an evidence of pre-registration increases,
Enthone is not in the position to provide such evidence today, due to the
following reasons:
- The period of pre-registration has not been finished yet.
- The European Chemicals Agency (EChA) provides a pre-registration number
per company and per substance (not per preparation - such as our products). Up
to today it is not clear, whether or not pre-registration numbers will be
communicated along the supply chain. It is expected that suppliers
general certificates of compliance will be the only legal binding evidence
in future.
- The importer or manufacturer is responsible for (pre-)registration of the
substance purchased by Enthone. Once he (pre-)registers, Enthone will
provide any relevant information in a timely manner, e.g. like the registration
number of a hazardous component in an Material Safety Datasheet.
Questionnaires/Certificates:
Please appreciate that Enthone does not fill questionnaires or sign statements,
due to the fact, that Enthone is a downstream user and that currently available
suppliers confirmations about (pre-)registration are only about their intention to
(pre-)register without any legal meaning. Enthone will do the utmost
to comply with REACh, but we expect certificates of compliance to be sent
by our suppliers at the earliest January 2009.
Material Safety Data Sheet (SDS):
The European Commission (EC) and the European Chemical Industry Council (CEFIC)
have defined that it is not mandatory to send updated SDSs before December
01, 2010, due to the continual changes in data while executing REACh. However,
this is not valid in case new information relevant to safety arises or when
authorities impose restrictions during registration of a product. In
such a case, an updated SDS needs to be sent promptly.
Application of a Product:
REACh requires an application description of a product within the SDS. The
application is a basis for estimating the risk of a product when used by humans
or when released to the environment. This will be of particular importance
when exposure scenarios need to be created.
The description of applications has been specified with the REACh Implementation
Project RIP 3.2-2 and has been published on May 29, 2008 (see http://reach.jrc.it/guidance_en.htm). On
this basis and in cooperation with the Central Organization for Surface Technology
in Germany (ZVO), Enthone actively creates standardized applications and exposure
scenarios for our branch of industry.
Substances of very high concern (SVHC):
The European Chemicals Agency (EChA) will publish a list of such substances
by June 2009. After discussion of this list, agreed substances will be transferred
to REACh Annex XIV. After a transition period, substances and their
applications are subject to authorization and therefore need to be documented
and communicated within the supply chain. Of course Enthone will follow
this duty as soon as possible.
We hope that this information has been sufficient to answer your questions.
If you have any further queries please do not hesitate to contact us.
Kind regards
Holger Quitzsch
REACh-Manager Europe