reach - modello di lettera produttore-fornitore - inglese
Transcript
reach - modello di lettera produttore-fornitore - inglese
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 Federazione delle Associazioni Nazionali dell'Industria Meccanica Varia ed Affine 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) 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 Federazione delle Associazioni Nazionali dell'Industria Meccanica Varia ed Affine 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 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