REACH Regulation (EC)

No 1907/2006 concerning Registration, Evaluation, Authorization and Restriction of Chemicals

November 17, 2008

On June 1, 2007 REACH came into force. It contains the following regulations:

1. From June 1, 2008, manufacturers of substances, and importers of substances as such or of substances in preparations (mixtures) into the European Community (EC) and the European Economic Area (EEA), must register these substances with the European Chemicals Agency if the substances in question are manufactured or imported in quantities of at least 1 t/a and if they are not substances that are exempted from compulsory registration. So-called "phase-in substances" – these are, for example, substances that are shown on the existing substances list EINECS – can be pre-registered between 1 June 2008 and 1 December 2008. Pre-registered substances do not have to be registered until later, depending on the quantity manufactured/imported.

2. Suppliers of substances and preparations must provide the recipient with either a safety data sheet (Article 31) or safety information (Article 32). In certain cases, the safety data sheet will be supplemented by an annex ("extended safety data sheet") showing the relevant exposure scenarios.

3. Manufacturers and importers of articles that contain more than 0.1 mass percent per article of a substance on the "candidate list" shall provide the professional recipient and on request a consumer of the article with sufficient information to allow safe use of the article, including, as a minimum, the name of that substance. If all these articles contain more than 1 t/a a notification to the European Chemicals Agency (EChA) is necessary, however, not before 1 June 2011.

4. From June 1, 2008, users of chemicals (substances and preparations/mixtures) – so-called "downstream users" – will have to comply with other obligations, but in some cases only after they have received an extended safety data sheet. Downstream users can provide appropriate information so as to assist the manufacturers of substances and importers of substances and preparations in registering them.

Lapp North America Response:

You procure articles (not chemicals) from us which are not intended to release any substance under normal and reasonably foreseeable conditions of use. Consequently, the obligations in No. 1 and 2 above are not relevant here.

Upon EChA’s publishing or updating of the "candidate list", we shall fulfill our obligations according to No. 3. We shall send you any necessary information once the relevant data is available from the supply chain. As far as we know at present, however, our articles do not currently contain any substances above 0.1 mass-percent per product that could be included on the candidate list.

Through communication with our chemicals suppliers we will try to safeguard the delivery of all chemicals which are necessary for us.

As far as REACH causes relevant modifications of products, affects our ability to deliver, or has an impact on the quality of our products, we will keep you informed within the scope of our business relationship. In individual cases we will consult you about appropriate actions.

For more information about REACH we recommend to use additional sources: www.eur-lex.europa.eu or www.reach.bdi.info.