• 1.1 REGISTRATION OBLIGATION
All substances in quantities of 1 ton or more per year need to be registered. Depending on the volumes and the hazardousness of the substance this had to take place in 2010, 2013 or 2018 and can include (expensive) tests to assess the effect on human health and environment. Substances already on the EU market had to be pre-registered before 1/12/2008 in order to stay in the European market after this date. If pre-registration is missed, the substances have to be withdrawn from the EU market.
Since the legislation came into force, Brady has been investigating the different responsibilities and its different roles to play under REACH.
As an importer, we have reviewed all the quantities we import into the EU. As we did not import a ton or more of any of the substances, we have no registration obligation.
As a down stream user, Brady has been in close contact with its suppliers to get the required confirmation that they, or their sub-suppliers, will register the substances in scope.
So far, Brady is happy to confirm that we do not expect any disruption in our supply chain due to the registration obligation.
• 1.2. SUBSTANCES OF VERY HIGH CONCERN (SVHC)
The European Chemical Agency (ECHA) will, based on the test results, determine whether some substances have to be restricted or need to be authorized for certain applications. Today there are already 138 SVHCs identified on the latest Candidate list of 19th December 2012 (http://echa.europa.eu/chem_data/candidate_list_table_en.asp), but more will be added by ECHA; 3000 substances (!) are currently under review.
Brady is in close contact with its vendors to review after every update of the Candidate List, if one or more of the SVHCs are present in the parts and materials we put on the European market. Under REACH it is an obligation to inform customers on the presence of a SVHCs >0,1% w/w in the products sold in Europe.
If there would be a product with SVHC present, Brady will inform its customers, including safe usage instructions. You can find detailed information on the status on SVHCs on a product level in the REACH search section of our website.
In the meantime 14 of the SVHCs from the Candidate List have been selected for the Authorization List (Annex XIV). Those 14 SVHCs cannot be put on the market anymore after “sunset date”. For those SVHCs that are currently on the Authorization List and that occur in our parts or materials, Brady is working closely with its vendors to redesign them to an “SVHC-free”’ version.
You will find the 2 publications of the Authorization List on:
The past few years, a whole European team has been working on the follow up of this legislation. In Europe, a team of local REACH coordinators has been established for each site. These coordinators are in close contact with the suppliers to obtain the requested SVHC information and are organizing the feedback on the customer requests. For specific questions related to our products and REACH, please contact your local sales or customer service representative.
FREQUENTLY ASKED QUESTIONS
See link Echa Europa FAQ
More information about the legislation can be found on:
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