Registration, Evaluation, Authorisation and Restriction of Chemicals
In the following, we explain the effects of the introduction of REACH / SVHC.
The Regulation (EC) No. 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals¹ (abbreviated as: “REACH”) became effective on 1-June-2007. SVHC (substances of very high concern) are chemical bonds (or part of a group of chemical bonds) for which the approval of application within EU is subject to the REACH regulation.
REACH contains the following regulations:
- Manufacturers of materials and importers of materials as such or of materials within preparations in the European Community (EC) and the European Economic Region must register these materials with the European Chemicals Agency as of 1-June-2008, as long as they manufacture or import quantities of at least 1 ton annually, and the materials are not one that are excepted from the duty to register. So-called “phase-in-materials”, for instance, such materials that are listed in the old materials directory EINECS, may be pre-registered between 1-June-2008 and 1-Dec-2008. Pre-registered materials must first be registered at a later time, depending on the amount manufactured / imported.
- Suppliers of materials and preparations must provide downstream users either with a Safety Data Sheet (Article 31) or safety information (Article 32). In certain cases, the Safety Data Sheet may be extended by an annex containing relevant exposure scenarios (“extended Safety Data Sheet”).
- Manufacturers and importers of products that contain more than 0.1% by weight per product of any material on the so-called “candidate list” must supply sufficient information to allow safe use of those articles to professional and downstream users upon demand, but at least but the names of the material(s). Additionally, if all of these preparations contain more than 1 ton per year the material, a notification must be sent to the European Chemicals Agency (EChA), but not earlier than 1-June-2011.
- Users of chemicals (materials and preparations), or so-called “downstream users” must satisfy additional responsibilities as of 1-June-2008, but only after receipt of an extended Safety Data Sheet. Downstream users may support material manufacturers and material importer through the preparation of relevant information for the registration.
We provide our customers with exclusively non-chemical products (preparations). In addition, under normal and reasonably to be expected usage conditions, no material should be released from the products provided to our customers. Therefore, the responsibilities according to numbers 1) and 2) do not apply here.
The Company Multi Circuit Boards Ltd. (Multi-CB) counts as a “downstream user” under 4). Thus, the duty to register does not apply.
We are also in close contact with our suppliers, and pay very close attention to the correct application of the REACH regulations and any required pre-registration, including the “candidate list”.
To our knowledge, none of our products contain any materials² above 0.1% by weight from the “candidate list”, nor any such as may be included in the “candidate list”! We will of course inform you immediately if a change in the “candidate list” should apply to our products, but this is not to be expected according to current information.
The Multi Circuit Boards Ltd. places extreme emphasis on dependability and deliverability.
¹ REGULATION (EC) NO. 1907/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL dated 18 Dec. 2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC, and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94, as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC.
² This applies to CMR (cancerous, mutating, reproduction-toxic) materials (in category 1 or 2 respectively), PBT (persistent, bio-accumulating, toxic) and vPvB (very persistent, very bio-accumulating) materials, as well as similar hazardous materials, which have been individually determined according to scientific criteria.