Certificates of REACH Compliance

Every year Sitmae provides Certificates of REACH compliance to the importers; the European clients of our customers. These certificates are highly appreciated. They prove that the importers’ REACH obligations have been taken over by us and they provide the necessary information for the importers’ records.

We certify that we are your REACH Only Representative and that under REACH your customers are simply Downstream Users. They no longer have the complicated importers’ REACH obligations. We certify which products and quantities we cover and that the substances have been pre-registered or registered or are perhaps REACH exempt. Where necessary we provide registration numbers and other relevant information.
The annual Certificates of REACH Compliance provide inspectors with the information they need. Inspectors may also contact us and inspect our records.

Our Certificates of REACH Compliance are always such that legal REACH requirements are met, but confidential business information is never released.

Resource By : http://www.sitmaereachservices.com/reach-services/reach-only-representative

 

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REACH Registration

REACH Registration is necessary by certain deadlines, depending on the annual volume marketed. We register substances for both our non-European and European customers.

Most registrations are ‘joint submissions’. A REACH consortium of active companies prepares the REACH registration dossier. Other registrants may join their registration. They must buy a ‘Letter of Access’ to the joint registration.

For joint submissions, our REACH registration service consists of:

• We determine by which deadline the substance must be registered under REACH.

• We find the right REACH consortium for your substance and determine the fee for the ‘Letter of Access’.

• We provide the customer with a short list of data that must be provided. If necessary we assist in collecting this data.

• We check together with our customer if the consortium’s substance ID exactly covers the customers’ substance.

• We acquire the ‘Letter of Access’ from the REACH Consortium.

• We complete the IUICLID registration dossier with the customer’s data.

• We determine with the customer if an SME discount can be obtained for the ECHA registration fee. (SME: Small and medium Sized Enterprise).

• We collect and record the necessary SME-proof from the customer.

• We submit the registration dossier to ECHA (European Chemicals Agency).

• We ensure payment of the registration fee to ECHA (European Chemicals Agency).

Sitmae is also capable of handling more complex REACH registrations. See our section on REACH consultancy.

Resource By : http://www.sitmaereachservices.com/reach-services/reach-registration

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REACH costs in the Aluminium industry

The European Aluminium industry has studied the overall cost resulting from of EU legislation. The REACH components in these costs were approximately € 45 million; a considerable amount, but only a small part of the total. (The costs related to energy legislation were far larger.) The registration costs alone were almost € 20 million for the 46 plants studied. Human recourse accounted for almost € 10 million.

Resource By : http://www.sitmaereachservices.com/posts/reach-costs-aluminium-industry

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Registrations in a non-EU supply chain

Non-EU formulators (producers of ‘mixtures’) may purchase substances that have already been registered by their non-EU supplier. Or they may buy substances that were registered by their European Manufacturer. Where this is the case, the importer or the non-EU formulator’s Only representative no longer needs to register the substances.

In practice it is very difficult to obtain adequate proof of such REACH Registrations. A simple letter giving the registration number and the tonnage band could be enough. But the registrants sometimes require signatures under complicated contracts, wish their own OR to have the contact details of all the formulator’s European customers and sometimes even regard their registration numbers as confidential business information. Lack of guidance and lack of knowledge of REACH makes for many different perceived problems and as many different solutions.

Kind regards,

Paul W.Verspoor MBA

Sitmae REACH Services BV
Phone: +31.346.562.414
PB 1644, 3600 BP Maarssen, The Netherlands
www.sitmaereachservices.com
reach@sitmae.com

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REACH Candidate List Obligations

When a substance features on the REACH Candidate List, this leads to obligations:

SVHC Information to be provided

When a Candidate List substance is used in a mixture (> 0,1%) this must be indicated on the Safety Data Sheet.

When a Candidate List substance is used in an article (> 0,1%), professional and industrial users must be informed.

In both cases Consumers must be informed within 45 days after at their request.

NGO’s provide standard letters with such SVHC Reach information requests.

SVHC Notification to ECHA

When a Candidate List substance is used in an article (> 0,1% and > 1 tonne per year), a Notification to ECHA must be submitted.

This applies also to imported articles.

SVHC Notification to ECHA can only be avoided if:

• Exposure to humans and the environment can be fully excluded (also in the waste stage!), or

• Someone has registered the substance in question for the particular use. (Registration not necessarily by the manufacturer of the substance)

If ECHA notification is avoided, the decision must be documented appropriately.

For More Information Please Visit Site : http://www.sitmaereachservices.com/what-is-reach/svhc-and-authorisation

 

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REACH Consultancy

Consultancy in Regulatory Affairs is Sitmae’s origin.

We help industrial companies comply with REACH and we lobby new legislation in Brussels on behalf of industrial trade associations. We have a distinct preference for technically complicated subjects. We were involved in REACH from its earliest conception.

As REACH consultants we have prepared a ‘REACH Roadmap’ for the members of six European trade associations. This document describes how to prepare their companies for REACH.

For More Information Please Visit Site : http://www.sitmaereachservices.com

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