As importer of several metals from non-EU countries we are under the obligation to register these metals. In the first registration phase we have registered copper, nickel and zinc.
For metals imported from EU countries we are regarded as a downstream user. In such cases we make sure that our suppliers have registered the respective metals. We will also ensure that the manufacture of semi-finished products is covered by the respective registration dossiers.
Substances of Very High Concern (SVHC) may become subject to authorization under the REACH Regulation.
The European Chemicals Agency (ECHA) published on its website a candidate list of Substances of Very High Concern for a possible inclusion in Annex XIV of the REACH Regulation.
The candidate list was last updated on 15 January 2018 and can be viewed at:
According to Article 33 of the REACH Regulation substances listed on the candidate list have to be reported if SVHCs are present in an article in a concentration above 0,1% weight by weight.
Our articles do not contain SVHCs listed on the candidate list in a concentration above 0,1 % weight by weight!
According to Article 33 of the REACH Regulation we fulfil our duty of communication towards our customers unprompted in case Substances of Very High Concern (SVHC) should be contained in one of our articles in a concentration of more than 0,1%.
Substances subject to authorization are listed in Annex XIV of the REACH Regulation. Annex XIV was last updated by the European Commission with Regulation (EC) No. 2017/999 on 13 June 2017.
The substances listed in Annex XIV are not contained in our articles!
According to the ECHA Guidance “Guidance on requirements for substances in articles (Version 2 – April 2011)” the following definitions apply:
Waste that leaves our company and has up to now been subject to the waste regime continues to be subject to the waste regime.
With the coming into force of the REACH Regulation (EC) No. 1907/2006 on 1 June 2007 the 91/155/EEC directive (Information on Safety Data Sheets) has been repealed.
The REACH Regulation defines the requirements concerning Safety Data Sheets and establishes the prerequisites concerning the legal obligations to provide Safety Data Sheets.
For articles, there is no legal obligation to provide Safety Data Sheets.
As our semi-finished products and our finished products are considered as articles according to the REACH Regulation, we will no longer provide Safety Data Sheets. Instead, an Information Sheet for Articles with respective data will be made available to our customers on a voluntary basis.
Material Safety Data Sheets (MSDS) according to the U.S. Hazard Communication Standard 29 CFR 1910.1200 will still be provided unchanged to our customer.