Information on the New EU Chemicals Policy

Dear customers,

the preregistration phase for the so-called ′phase in′ substances has ended. Starting December 1st 2008 only preregistered or registered substances are allowed to be produced in the EU, imported or be placed on the market if their ammount of 1 tonne per year will be exceeded.

Concerning the European REACH Regulation (EG) #1907/2006 (registration, assessment, approval and restriction of chemical substances) the Hugo Häffner group is in principle in the role of a downstream user and only very rarely in the role of a lead registrant. Therefore it was the responsibility of our suppliers to preregister and register the substances delivered to the Hugo Häffner group. So fal all our suppliers have confirmed their will to preregister respectively their preregistrations.

In the case of discontinuation of delivery on the part of a supplier we will inform our customers in a timely manner.

The Hugo Häffner group confirms to act REACH conform – at the present as well as in the future. This also includes the timely communication within the supply chain that is required as per REACH (e.g. information transfer concerning the content of substances of very high concern in the Häffner distribution program).

The REACH Regulation lays down that substances posing a significant potential hazard need to go through a process of approval. These substances will be referred to in the so-called candidate list (Annex XIV). This process of approval examines the availability of alternatives and their potential risk and at the same time the economic and technical feasibility.

You can see the candidate list on the following ECHA website: https://echa.europa.eu/de/candidate-list-table

The Hugo Häffner group will state substances of the candidate list on their safety date sheets (Chapter 3) if such substances are included in their products by more than 0.1 percent.

Best regards

The Häffner Team

Purpose and REACH

The intended purposes as reported by our customers will be – as request per REACH – communicated ′upstream′ along the supply chain. Though the registrants respectively manufactures only have a duty to inform the downstream user if an intended purpose cannot be taken into account. There is no duty on the part of the supplier to confirm an intended purpose as part of the registration dossier before a safety assessment (CSA) can be worked out. A purpose is only officially confirmed when the registration dossier has been accepted. The approved purposes will then be communicated via exposure scenarios in the extended safety date sheets. Safety data sheets and exposure scenarios need to be only worked out for substances and mixtures that have been classified as dangerous though.

We hope for your understanding if we cannot issue a confirmation in every single case. We are directly subject to the REACH Regulation. It is a matter of course to fulfil all requirements of the existing chemicals legislation. Should you require detailed information concerning REACH for a specific product please feel free to contact our internal REACH expert Mr. Stöckle.

 

E-Mail: markus.stoeckle@hugohaeffner.com

REACH Authorization Procedure

Substances of a very high concern will be included in the REACH Regulation Annex XIV gradually. After an inclusion has been successful the substances are not allowed to be brought into circulation or used unless the respective company has received authorization.

Substances of Very High Concern

Substances of Very High Concern are:

  • carcinogenic, mutagenic or teratogenic substances (CMR) of the categories 1 and 2
  • persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative substances (vPvP) in accordance with the criteria in the REACH Regulation Annex XII and / or
  • -in particular cases- identified substances for which there is scientific evidence that they probably have serious and alarming effects on human health or on the environment, such as the abovementioned substances, e.g. substances with endocrine disrupting properties.

Grounds and Procedures for Regulations

Dangerous substances of particular concern: their regulation is vital as their potential effect on people and environment could be severe and most of the time irrgeversible. For subtances which are subject to authorization there is no minium quantity. The authorization process requires a thorough assessment. The assessment´s results will be discussed in-depth before the appropriate decisions are taken.

Authorization in Practice

The authorization process consists of 4 steps. Industry has particular obligations in the third step. For steps 1 and 2 all interested groups have the possibility to make a contribution though.

Step 1: Identification of Substances of Very High Concern (by the Authorities)

Substances of very high concern can be identified according to the criteria mentioned before. This will be achieved through the relevant authorities of the member states or the agency (on behalf of the European Commission), namely by preparing a dossier according to Annex XV. Interested groups can comment on substances for which a dossier is present. The outcome of this identification preocess is a list of identified substances, which are candidates for prioritization (candidate list). This list will be published by the agency and updated periodically.

Review: All authorizations will be reviewed after a certain amount of time that is to be determined as the case arises.

Article 33 of the REACH Regulation regulates the obligation to pass on information on substances in goods.

  • every supplier of a good that includes a substance meeting the criteria of article 57 and determinedaccording to article 59, paragraph 1 in a concentration of more than 0,1% weight by weight provides the recipient of the good with sufficient information on the secure use of the good, at least though the supplier states the name of the respective substance.
  • upon request of a consumer, every supplier of a good that includes a substance meeting the criteria of article 57 and determined according to article 59, parafraph 1 in a concentration of more than 0,1 % weight by weight provides the consumer with sufficient information on the secure use of the good, at least though the supplier states the name of the respective substance.

Reference

Our Certificates