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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 an OR (only
representative) to provide services on
pre-registration, registration and other REACH
compliance obligations.
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 we
produce before December 1st 2008. As a
result, our products will be benefit from their
transitional periods for registration, respectively.
In all cases, we shall register substance of our
products before the pre-registration period get
expired, also we will make every effect to inform
our customers in good time if individual products
can no longer be supplied in the future.
Product
information and
pre-registration of substances, see table 1
|
Product |
Substance |
CAS No. |
Pre-registration number |
|
Rubber accelerator·
MBT(M) |
benzothiazole-2-thiol |
149-30-4 |
05-211*******-52-0000 |
|
Rubber accelerator·
MBTS（DM） |
di(benzothiazol-2-yl) disulphide |
120-78-5 |
05-211*******-58-0000 |
|
Rubber accelerator·
CBS（CZ） |
N-cyclohexylbenzothiazole-2-sulfenamide |
95-33-0 |
05-211*******-52-0000 |
|
Rubber accelerator·
TBBS（NS） |
N-tert-butylbenzothiazole-2-sulphenamide |
95-31-8 |
05-211*******-42-0000 |
|
Rubber accelerator
DZ（DCBS） |
N,N-dicyclohexylbenzothiazole-2-sulphena |
4979-32-2 |
05-211*******-60-0000 |
|
Rubber accelerator ZMBT |
zinc di(benzothiazol-2-yl) disulphide |
155-04-4 |
05-211*******-70-0000 |
|
Rubber antioxidant
4020(6PPD) |
N-1,3-dimethylbutyl-N'-phenyl-p-phenylenediamine |
793-24-8 |
05-211*******-38-0000 |
|
Rubber antioxidant
4010NA(IPPD) |
N-isopropyl-N'-phenyl-p-phenylenediamine |
101-72-4 |
05-211*******-43-0000 |
Registration
We are
participating in SIEF (Substance Information
Exchange Forum), dealing with date 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.
We shall support and monitor the necessary exchange
of information along the supply
chain. By dealing with the REACH legislation at an
early stage, we have taken advantage of the
possibility to recognize long-term opportunities and
consequences and to react accordingly. This ensures
the continuous supply and marketability of our
company’s products, and thereby ensures the
fundamental benefit of our customers.
We will
complete the registration of the substances list
below before November 30 2010. The registration of
other products will also be carried out one after
another before the corresponding deadline.
|
Product |
Substance |
CAS No. |
Registration deadline |
|
Rubber accelerator
MBT(M) |
benzothiazole-2-thiol |
149-30-4 |
30/11/2010 |
|
Rubber accelerator·
MBTS（DM） |
di(benzothiazol-2-yl) disulphide |
120-78-5 |
30/11/2010 |
|
Rubber accelerator
CBS (CZ) |
N-cyclohexylbenzothiazole-2-sulfenamide |
95-33-0 |
30/11/2010 |
|
Rubber antioxidant
4020NA(6PPD) |
N-1,3-dimethylbutyl-N'-phenyl-p-phenylenediamine |
793-24-8 |
30/11/2010 |
Substances of Very High Concern (SVHC)
ECHA
has published the second candidate list of SVHC on
January 13, 2010, there are 29 substances in total
currently (link), and the list will be updated
continuously. We have established a comprehensive
raw material database for our product, and will
check in time once a new candidate list published.
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 by conveying through updated Safety Data
Sheets or other relative documents.
If in
future we learn of legal developments that will have
a serious influence on the marketability or the use
of a substance, we will immediately notify you and
promptly offer alternatives.
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 are
welcoming REACH as an important contribution to
strengthening the preservation of the environment,
as well as a business opportunity, to develop
innovative solutions in order to replace hazardous
substances. 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. Please use the e-mail address
stated below – we will reply immediately:
Email:
wq-lsj@163.com
4. Link information
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