AEROPIA REACH UPDATE
January 2009

In the REACH process Aeropia is a supplier of chemical products. In addition Aeropia is also an importer of products containing chemical substances as defined under the REACH Legislation.

Aeropia as importer of products:

As an importer of products containing substances, Aeropia has pre-registered all substances where the annual volume of imports by Aeropia from non-EU countries exceeds one tonne as required by the legislation.

Suppliers to Aeropia

Our Suppliers have confirmed that, where applicable, substances used in products will be pre-registered. The intentions and decisions of our product Suppliers concerning pre-registration and registration of substances may lead to consequences for the use and availability of products.

We expect a in a few cases there will be some products which may no longer be offered due to possible potential raw material restrictions. As soon as we have exact information about a possible phase-out of product from our suppliers we will inform you and we will check if there is an alternative product.

REACH does not cover all substances

Please be aware that there may be substances in products we supply to you that require no registration under REACH. This is because they are exempt , for example, as less than one tonne of substance is imported into or made in the EU, or are naturally occurring substances, or covered by other legislation e.g. Biocidal Products Directive’ (BPD) 98/8/EC, which overrides REACH.

Pre-registration numbers

There is no legal requirement to transmit pre-registration numbers through the supply chain, and there is a common approach within the industry not to communicate this. A pre-registration number alone does not guarantee compliance with REACH.

Future Information developments

Software:
We have made a significant investment in software which will in the near future enable us to analyse substance data against product. As we are receiving data from Suppliers we are analysing and entering it onto a database. However, you must appreciate that there is a large volume of data entry required as we supply thousands of products.

Web based updates:
We will be publishing on our website REACH updates covering specific information regarding products we supply. This will cover deleted products, alternatives, SVHC information. We will be directing customer requests for information to the website

Substances of Very High Concern (SVHC’s)

We have received increasing numbers of enquiries about Substances of Very High Concern (SVHC)

The initial candidate list of SVHC’s was published in October 2008 and can be found at
http://echa.europa.eu/doc/press/pr_08_34_msc_indentification_svhc_20081009.pdf

ECHA will propose to the European Commission by 1 June 2009 the first substances that in its opinion should be placed in Annex XIV (Authorisation List). Substances that will be included in the Authorisation list cannot be manufactured or imported in the EU from a specific date set by the Commission, except if the companies have obtained an authorisation for their specific use(s).

Most of the products we supply are Preparations, although some are Articles.

Preparations:

From the date of inclusion on the SVHC Annex XIV (Authorisation List EU and EEA suppliers of preparations not classified as dangerous according to Directive 1999/45/EC have to provide the recipients, at their request, with a safety data sheet if the preparations contain at least one substance on the Candidate List and its individual concentration is at least 0.1% (w/w) for non gaseous preparations and at least 0.2% by volume for gaseous preparations.

Also legislation pre REACH required these substances to be identified on Safety Data Sheets

Articles

Notification is required under Article 7(2) of the REACH Regulation for substances of very high concern (SVHC) present in articles and for which the following conditions are met:
(1) the substance has been included in a candidate list for eventual inclusion in the list of substances subject to authorisation (Annex XIV) and
(2) the substance is present in those articles above a concentration of
0.1% weight by weight (w/w)
and
(3) the total amount in those articles exceeds one tonne per producer or importer per year and
(4) the substance has not yet been registered for that specific use.
However, there is no obligation to notify if the producer or importer can exclude exposure to humans or the environment during normal or reasonably foreseeable conditions of use and disposal

We therefore direct your attention to the Safety Data Sheets which we supply to you. Section 3 of the MSDS contains details of the hazardous products contained in the product. All the candidate SVHCs are defined as Hazardous under CHIP so will be detailed here”.
Customers may access Safety Data Sheets via our website INFOLINK service. If you have not already registered for INFOLINK, please go to our website and follow the instructions.

Other than via Safety Data Sheets, we will not be able to publish to you any further information analysing or identifying SVHC’s contained within products we supply to you at this time. We do anticipate benefits from the database software mentioned above which will enable us to carry out substance analysis, but this will require completion of the data entry program into, and final clarification from ECHA of the first substances actually placed in Annex XIV (Authorisation List).