Dear Customers,
According to Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH),
EU Regulation 1907/2006/EC, The first stage of REACH implementation, the pre-registration of ¡°phase-in¡± substances, has ended on December 1st 2008. We has completed pre-registrations of the volumes of substances in the commercial products that we manufacture, import and sell in the EU.
Our Implementation of the EU REACH Regulation:
1. How are we preparing for REACH?
We has given a very high priority to preparing for and implementing the requirements of the European Union¡¯s Regulation 1907/2006/EC on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). We has followed the development of REACH from an early stage, and actively supports relevant industry associations such as the European Council for the Chemical Industry (CEFIC) where We representatives actively participate in relevant REACH committees and task forces. We has a REACH Implementation Team that coordinates the different elements of the program to ensure successful and timely (pre-)registrations of the substances in our products. To date these elements have included the assembly of substance inventories, composition information, collection of information on substance properties, planning the gathering of required information on uses and exposure potentials, and completing the pre-registrations.
2. Will We pre-register and register the substances that We produces, imports and sells in the EU?
We has completed pre-registrations of all the products (substances) it manufactures, imports and sells in the EU*. We intend to complete full registrations by the relevant deadlines. We¡¯s product portfolio is subject to the normal periodic business review. Because the registration period for the lowest volumes extends until 2018, it is not possible for us to provide statements guaranteeing full registration at this point. We is intending to ensure that all products it currently manufactures, imports and sells in the EU will be REACH compliant and we do not expect any of our products will be taken off the market because of REACH.
* European Economic Area: the 27 member states of the EU plus Iceland, Liechtenstein, and Norway.
3. Will We provide product composition information that may be required for the preparation of a registration dossier (non-EU customers)?
We will provide details of the compositions for most of its products to assist in the preparation of a REACH registration dossier. We may require a Non-Disclosure Agreement if the composition is regarded as confidential. Customers needing REACH composition information should contact our Sales Representative.
4. Will you cover my use of our product in the registration dossier?
We expects to support all major uses of our products known to us and will contact our customers for more information as required concerning product uses and applications.
5. What measures have you taken to ensure that your suppliers are REACH compliant?
We is working closely with the suppliers of raw materials and other substances used in the EU manufacture of our products to ensure REACH compliance and supply continuity.
6. Has you updated the MSDSs to comply with the REACH requirements on format and content?
REACH requires a change in the format of Safety Data Sheets (MSDS) and the addition of an email address. Following discussions in the second half of 2007 between industry bodies, the European Commission, and the EU national authorities, the current understanding is that a transitional period will apply until December 1st 2010 for adoption of the new format. If a substantial revision to the content of an existing MSDS, or a new MSDS is required the
document should use the new format. We is currently implementing a new MSDS management system and will adopt the REACH format when this program is completed. The current versions of We¡¯s MSDS are available on request.
7. Will any products / substances be subject to authorization?
None of the substances in our products are considered as substances of very high concern and none are on the first candidate list published by ECHA. We has no reason to believe that any of our products/substances will be subject to authorization.
8. Can you provide me with more information about REACH and the obligations that it brings?
We encourage all stakeholders to familiarize themselves with the REACH requirements by visiting the European Chemicals Agency (ECHA) website where there are comprehensive guidance documents and REACH help tools available. The link to this site is: http://echa.europa.eu/
9. Should I have questions about We¡¯s REACH implementation, how should I contact the responsible person?
Please direct all enquiries about REACH to your usual Service Representatives.
REACH Team
Metall Rare Earth Limited
December 9, 2008
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