REACH – for a transparent supply chain
Our customers write to us referring to the new EU chemical regulations 1907/2006 – REACH, reminding us as a supplier of the commitments and responsibilities resulting from this law.
In these letters customers point out that they are concerned whether all those belonging to the supply chain actually understand their commitments and whether they will take the necessary measures on time. Quite often these letters include questionnaires, which follow the “Automotive Industry Guideline on REACH” the European Automobile Manufacturers’ Association (ACEA).
According to REACH, only raw materials have to be registered. Regarding the rubber compounds supplied for the production of your products, we, as a “downstream” user, are dependent on the registration by our compounders and in turn they are dependent on the statements of their raw material suppliers.
As defined in the regulations, the rubber compound items we supply are, without exception, all defined as products. As you will know, these do not have to be registered. However, as far as possible we check with our suppliers to make sure that all raw materials, as well as those being prepared, are pre-registered on time.
At this moment in time we can presume that, for the most part, all the components used in rubber compounds are pre-registered and will also be available after the 1st December 2008.
In case our compounders inform us that certain raw materials are not registered, and have to be taken from the market by the 1st December 2010 at the earliest, as our customers we will inform you in time of any possible substitution measures.
Please do not hesitate to contact us if you have any questions about REACH: