MENTOR STATEMENT TO CONVERSION BY REACH (Registration, Evaluation, Authorisation of Chemicals)

To the new REACH prescription the countless inquiries which is written into the bargain in the most different interpretation and interpretation of the activities within the REACH application lately reach us. According to appraisal of the asking for customer a more or less obliging confession of the activity as well as of own security is demanded.
Our point of view to within the demanded activities within the REACH prescription or at the moment necessary measure is as follows:

REACH contains the following regulations:

1. From 1 June 2008, manufacturers of substances, and importers of substances as such or of substances in preparations (mixtures) into the European Community (EC) and the European Economic Area (EEA), must register these substances with the European Chemicals Agency if the substances in question are manufactured or imported in quantities of at least 1 t/a and if they are not substances that are exempted from compulsory registration. So-called "phase-in substances" – these are, for example, substances that are shown on the existing substances list EINECS – can be pre-registered between 1 June 2008 and 1 December 2008. Pre-registered substances do not have to be registered until later, depending on the quantity manufactured/imported.
2. Suppliers of substances and preparations must provide the recipient with either a safety data sheet (Article 31) or safety information (Article 32). In certain cases, the safety data sheet will be supplemented by an annex ("extended safety data sheet") showing the relevant exposure scenarios.
3. Manufacturers and importers of articles that contain more than 0.1 mass percent per article of a substance on the "candidate list" shall provide the professional recipient and on request a consumer of the article with sufficient information to allow safe use of the article, including, as a minimum, the name of that substance. If all these articles contain more than 1 t/a a notification to the European Chemicals Agency (EChA) is necessary, however, not before 1 June 2011.
4. From 1 June 2008, users of chemicals (substances and preparations/mixtures) – so-called "downstream users" – will have to comply with other obligations, but in some cases only after they have received an extended safety data sheet. Downstream users can provide appropriate information so as to assist the manufacturers of substances and importers of substances and preparations in registering them.

Statement:

You procure articles (not chemicals) from us which are not intended to release any substance under normal and reasonably foreseeable conditions of use. Consequently, the obligations in No. 1 and No. 2 above are not relevant here.

Recently the department in charge, the ECHA (European Chemicals Agency), has begun adding substances of very high concern for authorisation to the so-called “Candidate List” continually. We regularly crosscheck for our part the state of the Candidate List as regards the products we receive being listed. In case of a positive result of such check we inform the corresponding customer who obtains this product.

Through communication with our chemicals suppliers we will try to safeguard the delivery of all chemicals which are necessary for us.

MENTOR GmbH & Co.
Präzisions-Bauteile KG