Reichhold is well aware of REACH and is committed to achieving compliance with this new European chemical regulation in close cooperation with our valued customers and suppliers. We have had a multi-disciplinary team in place since early 2007 to understand REACH and prepare for its successful implementation.
REACH is substance-based, not product-based. Most of the products that Reichhold manufactures in the European Union and the European Economic Area contain polymers, which are exempt from registration under REACH. In accordance with REACH and guidance issued by the European Chemicals Agency (ECHA), Reichhold’s European plants pre-registered monomers used to manufacture polymers in their products. As a downstream user, we have also received assurances from our suppliers that they or their upstream suppliers have pre-registered the relevant monomers and other chemical substances in raw materials supplied to Reichhold.
Reichhold, Inc., Reichhold do Brasil Ltda., and Reichhold Quimica de Mexico, S.A. de C.V. which manufacture products outside the EU, have appointed Reichhold UK Ltd. as their Only Representative. Reichhold UK Ltd. pre-registered various substances in 2008 to allow continued import of selected products and quantities into the EU by designated European importers pursuant to separate agreement. We anticipate that such products will continue to be available in the EU through the applicable registration deadline, the earliest being 30 November 2010, and in some cases 31 May 2018. Business decisions to register substances will be made in the future as more information becomes available.
The Safety Data Sheet (SDS) will be the main tool for communicating hazard information, risk management measures, and exposure scenarios with our European customers as various provisions of REACH are implemented. Customers should follow our advice on measures to control risks and inform Reichhold of their uses and any new hazards so this information can be communicated up the supply chain.
Questions concerning our REACH position or preparations should be directed to Reichhold's REACH coordinators,
maria.loffellehner@reichhold.com within the EU, or
barry.clayton@reichhold.com outside the EU.