reach - modello di lettera produttore-fornitore - inglese

Transcript

Federazione delle Associazioni Nazionali
dell'Industria Meccanica Varia ed Affine
Unione costruttori
impianti finitura
REACH
MODELLO LETTERA PER COMUNICAZIONE TRA IMPRESE E FORNITORI
REACH: communication in the supply chain
DRAFT standard letter to suppliers on pre-registration/registration
Object: REACH Regulation N°1907/2006
Dear Supplier,
The European “REACH” Regulation 1907/2006 on the Registration, Evaluation, Authorisation of
Chemicals entered into force on 1 June 2007 and will have an important impact on the
availability of substances and preparations on the market. You may know that according to
REACH, substances in volumes of one tonne and more per year must be neither manufactured
nor imported in the EU, nor put on the market after 1 June 2008 unless they are registered.
Registration concerns substances on their own, in preparations and in articles in case of
intentional release of the substance.
In order to be granted transitional periods varying from 3.5 to 11 years for registration
(depending on substance volumes and type of substances), substances on their own/in
preparations/intentionally released from articles1 already on the market must be preregistered to the European Chemicals Agency between 1 June 2008 and 1 December 2008.
Missing pre-registration means that those substances must be registered before being further
manufactured, imported or put on the market.
Pre-registration and registration is only allowed for EU based legal entities. If you are based
outside the EU, we strongly recommend that you appoint an “only representative” (that is an
exclusive representative) in the EU, which will take over the pre-registration and registration
duties.
You can understand that we need to ensure supply sustainability and anticipate possible
changes of the substance or preparation we use, as well as process re-approval. For these
reasons, we wish to know if all substances on their own, and/or all substances in preparations
and/or all substances intentionally released from articles you supply to us are intended to be
pre-registered and registered. If it is not the case, we need to know if the production and/or
1
Please note that no registration of substance intentionally released from an article is required
if the substance has already been registered for that use (Article 7.6 REACH).
UCIF - Unione costruttori impianti finitura
via Scarsellini 13 - 20161 Milano | tel. +39 0245418.519 - fax +39 0245418.716
[email protected] - www.ucif.net - Cod. Fisc. 80067530156
Unione costruttori
impianti finitura
commercialization of the substance/preparation is to be abandoned, or the composition
changed. To ensure smooth continuity of business, we strongly recommend that you make
sure that all substances on their own and/or in preparations and/or intentionally released from
articles that you supply to us are going to be pre-registered and registered.
Therefore, for the substances/preparations/substances intentionally released from articles you
supply to us and listed in Table 1, please fill in the following information:
Your
role as manufacturer (M), importer
(I),
distributor (D), formulator (F),
downstream user (DU), article supplier (AS) according to REACH.
For substances/preparations you are considered as importer/manufacturer in quantities
above 1 ton per year per legal entity, please indicate if you intend to pre-register
between 1 June and 1 December 2008, and register them (Y/N):
o all substances on their own, and/or
o all substances in preparations
If you don't know this information yet, please indicate the date by which you estimate
to have this information available (mm/dd/yy). Please return this information to us as
soon as available.
For substances/preparations you are considered as distributor or formulator, or
downstream user or article supplier, please indicate if the upstream substance
manufacturer/importer intends to pre-register between 1 June and 1 December 2008
and register all substances on their own and/or all substances in preparations (Y/N). If
you don't know this information yet, please indicate the date by which you estimate to
have this information available (mm/dd/yy). Please return this information to us as
soon as available.
If you are located outside the EU, please indicate whether you will nominate an “only
representative” (Y/N) in the EU.
Are there any substances in their own/in preparations/in articles within the inventory
considered of “very high concern” that may be subject to Authorisation and/or that are
subject to the first registration period? (Y/N)
Unione costruttori
impianti finitura
TABLE 1 (with some examples)
EINECS if
available
Name
Company code
Substance 1
Substance 2
AX-111-223
SD-212-344444
FF-2344-223
12-34 -5678
22-45 -6789
FGH-2344678-00
ARS-243-123
-
Preparation
1
Preparation
2
Article
releasing
intentionally
substance 3
Role
Intention to
pre-register/
register
or information
available by…
M
Y
D
10/11/2007
F
N
F
Y
AS
12/12/07
-
33-56-1234
For suppliers
outside the EU
only nomination of
“Only
Representative”?
Substance of
very high
concern
according to
Art. 57 (1)
Y
N
N
N
N
Please provide full contact details for the person in your company responsible for REACH issues
(name, position, telephone number, mailing address and email).
Be
aware
that
by
XX
of
XX
XXXX,
we
will
request
other
information
on
the
substances/preparations you supply to us, regarding our identified uses/use and exposure
category to be included in the registration dossier of the substance, according to Article 37
REACH. We will also require further information on substances present in articles, with no
intended release, which are of very high concern.
Please return this questionnaire to:
Yours sincerely

reach - modello di lettera produttore-fornitore - inglese

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