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REACH Compliance |
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In response to an increasing number of customer inquiries on the European REACH regulation, this letter has been developed to identify actions taken and planned in response to the regulation. I have been designated as the primary contact for Environmental questions, including REACH.
We have been evaluating REACH since February, 2008. As a result of an extensive review of the regulation and guidance documents available from the REACH website, we have determined our responsibilities and actions as follows:
1. We are not planning on pre-registering any substances for REACH.
2. We are an article manufacturer and an article manufacturer does not typically pre-register substances. The scenario where an article manufacturer would need to pre-register is when substances in articles are intended to be released in an amount exceeding one metric ton per year. For the products that we manufacture, there are no substances that are intended to be released into the environment.
3. The ECHA website (http://echa.europa.eu/) currently lists (15) substances that have been accepted for inclusion in the Candidate List of Substances of Very High Concern (SVHC) subject to authorization (reference October 28, 2008 and November 4, 2008 news releases on ECHA website). We do not believe that we have any of these substances in amounts greater than 0.1% w/w in our standard solenoid products.
4. We are in the process of gathering information on continued availability of subcontracted materials where we perceive a risk of potential supply chain interruption due to the REACH regulation.
5. Customers which require verification that our products sold to them do not have the SVHC that have been nominated for inclusion in REACH Annex XIV will be subject to a $2,500 fee (U.S.) per assembly part number in order to obtain the necessary documentation on component parts and materials.
6. We will continue to monitor the ECHA website for nomination of additional substances for inclusion in the candidate list of SVHC and will provide required 'notification' in accordance with Article 7 of REACH or 'communication' in accordance with Article 33 of REACH to affected customers should we determine that any substance added to the list is in our products in an amount greater than 0.1% w/w .
In addition to the solenoid products manufactured in Vandalia, Ohio by Saia-Burgess Inc., we are also the North American distributor for Saia, Burgess, BAR and TH-Contact switches, sensors, and Saia motors. REACH inquiries related to these products will be forwarded to the corresponding global manufacturing location for a response.
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