REACh Position Statement
November, 2008 : Collierville, TN
The purpose of this communication is to advise our customers of AOC, LLC intentions for REACH compliance.
REACH (Registration, Evaluation and Authorization of Chemicals) entered into force in all countries of the European Union (EU) beginning June 1, 2007. REACH is the new single regulatory system for chemicals management in the EU. It will require all EU based manufacturers and importers of Chemical substances to register their products with the new European Chemicals Agency (ECHA) by certain dates (according to the volume and classification of the substance). In order to "qualify" for these "extended" deadlines, it is necessary to pre-register all phase-in (existing) substances by December 1, 2008. The legal responsibility to ensure that imported substances are registered and fully compliant with all aspects of the REACH legislation rests with the importer established within the EU. Manufacturers based outside of the EU are unable to pre-register directly with ECHA but can appoint an Only Representative (OR) who can then relieve importers of this registration obligation.
While polymers are exempt from the scope of the legislation, the monomers and certain additives used in the manufacture of the polymer product are not exempt and must be pre-registered by the manufacturer / importer.
AOC, LLC is fully committed to meeting the REACH compliance requirements for products that are imported into the EU. As a part of our strategy, AOC, LLC has appointed the below identified company to act as our Only Representative (OR) according to article 8(1) of the REACH regulation (regulation 1907/2006/EC).
INTERTEK Semko Service AB,
A company, incorporated under the laws of Sweden, having its head offices located in Torshamnsgatan 43, SE164 22 KISTA, SWEDEN registered to the commercial registrar of 556161-6953.
Only Representative Contacts
Salman Khan
salman.khan@intertek.com
Angelique Pereira
angelique.pereira@intertek.com
AOC, LLC intends to pre-register with ECHA all substances which it imports into the EU by the December 1st, 2008 deadline. Pre-registration and registration will be conducted by our Only Representative and will also cover the substances (including, if applicable, substances intentionally released from articles) purchased from us by your company with the following caveats:
1. AOC, LLC will pre-register substances and be in compliance with REACH regulations for all EU importers and customers that are supplied directly from any AOC, LLC location within the United States or Canada. Your annual importation volumes will be reported to our Only Representative. If you require a Declaration of REACH Compliance (DRC), please contact our Only Representative, myself or your local AOC, LLC sales representative.
2. If you purchase AOC, LLC products outside the EU and take delivery in the United States or Canada and then import then into the EU as an article or substance, then AOC, LLC will not be able to issue you a Declaration of REACH Compliance (DRC) unless you do both of the following:
a. Provide to our OR the name, address and respective volume of impacted AOC, LLC products exported to each EU importer.
b. Report this information on a minimum yearly basis and within 60 days following the end of the calendar year
EU importation volumes are required by our Only Representative to support substance(s) volume registration under REACH. Our Only Representative is obligated to track the product substance volumes directly supplied by AOC, LLC that are imported into the EU on an annual basis.
If you purchase AOC, LLC products outside the EU, take delivery in the United States or Canada and then import them into the EU as an article or substance, then you must confirm your acceptance of the terms found in paragraph 2 (above) to the AOC, LLC Only Representative. Upon receipt of your acceptance of these terms, AOC, LLC will issue you a Declaration of REACH Compliance (DRC).
Should you have any REACH questions regarding AOC, LLC products, REACH legislation or a request for a Declaration of REACH Compliance (DRC), please contact one of the following: 1. Intertek, our Only Representative
2. Your AOC, LLC sales representative
3. Director of Regulatory Affairs, Frank Sizemore fsizemore@aoc-resins.com
Cell: 901-493-5636
Office: 901-854-2850