Roermond, September 2008
Re: REACH
Dear Customer,
REACH is the regulation for Registration, Evaluation, Authorization and Restriction of Chemicals. It entered into force on 1st June 2007 to streamline and improve the former legislative framework on chemicals of the European Union (EU). REACH places greater responsibility on industry to manage the risk that chemicals may pose to the health and the environment. (referenced in the REACH guidance published by European Chemicals Agency (ECHA))
Sekisui Jushi is well aware of the REACH regulation, as published, will have significant impact on all manufacturers, importers and downstream users in the European Union.
There are different roles of companies under REACH, which is determined by the activity they carry out with a substance. We understood Sekisui Jushi, a processing manufacturer, is classified as a “Producer of Articles” or “Downstream User” under categories designated by REACH, and the role in this category can be translated in brief that to manage the risks posed by chemicals contaminated in the articles or uses of chemicals in the process of making such articles. Downstream users must communicate information on dangerous substances and preparations down the supply chain through so called Safety Data Sheets (SDS).
We also make a note that under REACH polymers which is a main component of our strapping products are exempted from regulation. There are few other types of filler or additives composed of our products, however, those plastic materials are recognized as preparations (the polymer part, residual monomer, additives, etc.). Under REACH preparations do not need to be registered separately. Only the substances used on their own are subject to registration obligations.
Sekisui Jushi has started communicating with its suppliers to ensure that the substances used in their plastic materials will be registered on time for the identified use. We are currently receiving many questionnaires from our customers on REACH. However, at this moment it is still too early for some questionnaires and we are waiting for more information coming from upstream suppliers.
We will keep you informed of progress on REACH and in the meantime, for any questions or further information you may have or require, please contact our customer service.
Sincerely yours,
Management of
Sekisui Jushi B.V.
