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REACH Compliance Declaration


1. REACH regulation


REACH stands for"Registration, Evaluation, Authorization and Restriction of Chemicals" and is an EU regulation that came into force on June 1, 2007. This regulation redefines the European chemicals policy. It is an important step in the harmonization of chemicals legislation within the European Community. According to the basic principle "No data no market", EU manufacturers and importers of chemicals in quantities ≥ 1t/a are required to provide scientific evidence for the safe use of chemicals. For any products based on chemical substances within EU, compliance to REACH regulation requirements is inherent in the fact.


2. REACH process


OR appointment

In order to fulfill the obligations under REACH regulation, we have appointed RCS (REACH Compliance Services), located in Ireland, as our only representative(OR) to provide services on pre-registration, registration and other REACH compliance obligations in EU market.


Pre-registration

We intend to retain our present product range. Based on our current product portfolio, we have successfully completed the pre-registration for the substances. As a result, our products will be benefit from their transitional periods for registration, respectively. Product information and pre-registration of substances, see table 1


No

Name

CAS-No

EC-No

(Late) Pre-Registration No.

1

Chloroxylenol

88-04-0

201-793-8

17-21199619*****-0000

2

Di-Chloroxylenol

133-53-9

205-109-9

17-21199619*****-0000

3

Chlorocresol

59-50-7

200-431-6

17-21199619*****-0000

4

3,5-Xylenol

108-68-9

203-606-5

17-21199619*****-0000

5

Triclosan

3380-34-5

222-182-2

17-21199619*****-0000

6

Isophorone

78-59-1

201-126-0

17-21199619*****-0000

7

Mesityl Oxide

141-79-7

205-502-5

17-21199619*****-0000

8

Triclocarban

101-20-2

202-924-1

17-21199619*****-0000


Registration

We are participating in SIEF (Substance Information Exchange Forum), dealing with data sharing, classification and labeling harmonizing. We are pursuing an efficient registration strategy, and we will submit our registration dossier before relevant deadline. Our downstream information will be included into the registration dossier. Anyone in the same supply chain will securely export/import/use your products containing our substances under the REACH regulation. This ensures the continuous supply and marketability of our company's products, and thereby ensures the fundamental benefit of our customers.


Substances of Very High Concern (SVHC)

ECHA has published 144 substances on the list of SVHC, and the list will be updated continuously hereafter. We certificate that the products manufactured or assembled in our company will not contain any SVHC, or in case when SVHC exists with a concentration below 0.1%. If our product contains any of substances in the SVHC list above a concentration of 0.1% (w/w), we will inform you the required information and offer alternatives in accordance with REACH.


3. Fit for REACH


Here, we can promise our customers: We are "Fit for REACH".

We will invest in the processes and systems required to ensure that ongoing compliance can be maintained effectively, and take advantage of the portfolio optimization and sustainability platform that Reach offers. We will continue to ensure smooth business processes in the future.

We see the implementation of REACH as a future opportunity more than a current challenge. The faithful collaboration with our customers will be augmented and communication will deepen. We want to make this communication so effective that it becomes a business advantage for everyone.

Hereafter we will inform your customers of the status of our REACH implementation continuously. If you have any questions about REACH in connection with products, please contact us. Confidentiality will be maintained.