For years we are actively campaigning for a responsible use of chemicals and environment, a safe manufacturing of products and a riskless application of these products by our customers.
EC regulation no. 1907/2006 – REACh deals with the Registration, Evaluation, Authorization of Chemicals. Since its coming into force on the 1st of June 2007 it centralizes and simplifies the pan-European chemical law. According to the REACh regulation all substances that are being produced or imported in amounts of more than 1 ton annually have to be registered. This is valid for the substances themselves as well as for substances in mixtures and substances that are being released by commodities.
Setral Chemie GmbH initiated the necessary steps to assure the availability of all Setral products in the future. This of course encloses pre-registration respectively registration of all raw materials that we buy or produce ourselves. Till the deadline on 12/01/2008 all raw materials (et al. thickener) that are being produced or possibly could be produced have been pre-registered. All products placed on the market by Setral are by definition “preparations” that do not have to be registered at the European Chemical Agency (ECHA) in Helsinki, Finland. In contrast substances that are being used for the production of some of our products (greases), are compulsory to registration.
Particularly we contacted our EU suppliers of whom we purchase chemical substances that we use during our manufacturing processes. Our processes are mainly widely-used operations that are being applied by numerous sectors in high tonnages. Behind this background many of our suppliers signalized that the pre-registration respectively registration of the relevant substances has been arranged respectively a later registration is going to be done.
Thus from today’s point of view we can guarantee the delivery of all Setral products in usual quality and quantity in the future.
In order to efficiently and coordinated fulfill our duties regarding REACh we joined forces with other European grease manufacturers in the ERGTC (European REACh Grease Thickeners Consortium). We are going to register our grease thickeners at the ECHA from 2013 to 2018.
A further part of REACh is the so called list of candidates (SVHC = Substances of Very High Concern). This list contains substances that are of special interest on the part of ECHA. The list of SVHC-substances currently enfolds 138 substances (updated on 12/19/2012) and is published on the homepage of the ECHA under http://echa.europa.eu/chem_data/candidate_list_table_en.asp.
According to article 33 of the REACh regulation we are subject to reporting requirement to our customers in case a worrisome substance (SVHC) is contained in our delivered product with a mass concentration of more than 0.1 percent. It is our own concern that behind the background of a high delivery and product safety we take this reporting requirement very seriously. We comply with the statutory provisions according to article 33 of the REACh regulation by following procedure;
Our EU-suppliers are committed to promptly inform us without the necessity of a further request in case one of their delivered products contains a SVHC of more than 0.1 mass percentages. As soon as we have that information we are directly going to forward it to you according to article 33 of the REACh regulation.
We make separate agreements with our non-EU-suppliers since they are not automatically liable to the REACh reporting requirement. Thus, we have written commitments with them that they have to instantaneously inform us if one of their delivered products has SVHC-concentrations above 0.1 mass percentages.
Should you still have further questions on the implementation of the REACh regulations in our company, please do not hesitate to contact us. The appropriate contact person for all REACh topics is Mr. Dr. Alexander Grechin.