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REACH
Dear Valued
Customers of Habich GmbH,
we
would like to give you a short introduction to the new European
chemicals legislation and some information about the resulting
implications and the relevant positioning of Habich GmbH concerning
this issue.
The European
Parliament passed the Regulation (EC) No 1907/2006 ("REACH") on
18.12.2006 in Brussels and on 01.06.2007 it entered into force. In
the future, chemical materials may only be manufactured and marketed
within the European Union if they are registered. Accordingly, the
production or the import of substances in volumes over 1 metric ton
per year has to be announced to the European chemical agency (ECHA)
with its headquarter in Helsinki.
To prepare our
company for the REACH-directive, we have compiled an internal
schedule. This will ensure that we are able to accomplish all
requirements and liabilities regarding our product portfolio. As far
as possible we attempt to maintain the full availability of our
products in the future.
In the pre-registration
phase between 01.06.2008 and 01.12.2008 we intend to submit all
essential data of the products we manufacture or import into the EU
in order to benefit from the transitional periods. Hence we can
assure their uninterrupted supply at least until 01.12.2010. In the
case of chemical materials not manufactured by our company we will
be in close contact with our suppliers to clarify and ensure their
unconditional availability.
We also intend to
complete the entire registration of our products individually or as
a member of a Consortium. It is important to know that down-stream
users are involved in the registration procedure too.
In
case of
hazardous substances and
preparations, the registrant has to generate exposure scenarios
including the description of human and environmental exposure to the
material during its manufacture or use. These scenarios should cover
all identified uses of the registrant as well as the applications on
the part of the down-stream users.
To elaborate an
exposure scenario we may be required to contact you for specific
user information. Of course we will make such inquiries only out of
absolute necessity and will ensure we handle your response in a
strictly confidential way.
We will keep you
up-to-date about progress within the implementation of REACH. For
questions and detailed information regarding REACH please contact
Dr. Markus Richter (+43/2752/71472-23;
richter@habich.com).
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