DECLARATION BY MENTOR ON THE IMPLEMENTATION OF REACH (REGISTRATION, EVALUATION, AUTHORISATION OF CHEMICALS)
We regularly receive enquiries on the REACH legislation which differ greatly in their understanding and interpretation of the activities within the scope of application of REACH. Depending on the assessment of the enquiring customer, a more or less binding commitment is required, in terms of the activity itself but also to ensure their own protection. Our position regarding the activities required under REACH and/or any necessary measures is as follows:
As of 1 June 2008, manufacturers of substances and importers importing substances either on their own or in preparations into the European Union (EU) and the European Economic Area (EEA) must register those substances with the European Chemicals Agency if they are produced or imported in quantities of 1 t/a or more and to the extent that they are not substances exempt from registration. Substances referred to as „phase-in substances“ – these are for example substances listed in the EINECS inventory of existing chemical substances - can be pre-registered between 1 June 2008 and 1 December 2008. Pre-registered substances only need to be registered at later times, depending on the quantity produced/imported.
Suppliers of substances and preparations must provide their customers either with a safety data sheet (Article 31) or with safety information (Article 32). In certain cases the safety data sheet includes an annex outlining relevant exposition scenarios („extended safety data sheet“).
Manufacturers and importers of articles that contain a substance included in the „Candidate List“ in a concentration above 0.1 % weight by weight (w/w) must, on request, provide their professional customers as well as consumers with enough information to ensure the safe use of the article, but at least with the name of the substance. If the substance is also present in all those articles in quantities totalling more than 1 t/a, the European Chemicals Agency (ECHA) must be notified, but only from 1 June 2011 at the earliest.
Users of chemicals (substances and preparations), referred to as „downstream users“, must meet additional obligations from 1 June 2008, but only after having received an extended safety data sheet. To support the manufacturers of substances and importers of substances and preparations, downstream users can provide them with pertinent information for the registration.
REACH Declaration of Conformity
The article referred to below is a non-chemical product (article). In addition, no substance is intended to be released from this article under normal or reasonably foreseeable conditions of use.
Pointer knob aluminium; black mat; grub screw; d=6; W=19,5
Article contains substance(s) that is (are) listed in the REACh candidate list (SVHC) above 0.1 weight %: Lead (CAS-Nr.: 7439-92-1).
The candidate list is continuously revised by the competent authority, the ECHA (European Chemicals Agency), and supplemented with substances of concern. This declaration refers to the status of the REACh candidate list valid at the time of printing. The current status of the REACh candidate list is checked here with the incoming supplier information. Therefore, there may be delays in the up-to-dateness and data transfer. If SVHC substances are found in our products, information about the substance of concern is provided under the listed important notes.
This declaration is made to the best of MENTOR’s knowledge and is based on information provided to MENTOR by manufacturers and suppliers.
If you have any questions please contact the responsible department at: email@example.com
MENTOR GmbH & Co.
D - 40699 Erkrath