REACH    /   Information -# 5   /   Status: July 2010

With effect on June 1^st, 2007, the new Chemical Regulation of the European Union “Regulation (EC) No. 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)” came into force. REACH regulation will radically change the European chemical law. It is valid in all countries of the European Union and regulates the implementation, production and application of all chemicals. It protects human health and the environment. The regulation is based on the principle of a stronger responsibility of the industry for a safe handling of their substances. For manufacturers and importers this means they have to analyze the risks coming from substances they have manufactured or placed on the market and to suggest measures for a safe handling.

REACH at Schlenk Metallfolien

Regulation (EC) No. 1907/2006 includes measures, which have to be taken in between given time frames beginning from 1st of June 2008 on.

Due to the type of our business (cold rolling mill) and for metals purchased from EU-countries we are defined as downstream user and don’t have to pre-register.

To take advantage from transition periods and as a safety measure we pre-registered all relevant substances

Definition of substance, preparation and product

Due to the stipulated definition of substance, preparation and product in the “Guidance on requirements for substances in articles” we regard cast formats (cakes) as substance and alloys as preparations and thereof produced semi-finished products as products. Pure selected secondary metals we categorize like the pre-material they were part of.

Definition

Pre-registration and registration

On 30^th November 2008 the pre-registration period ended. We analyzed all our products in regard to REACH. For metals purchased from EU-countries we are defined as downstream user and don’t have to pre-register. According to regulation we will make sure that our suppliers will pre-register and register the respective metals. Meanwhile we got confirmation from all our suppliers that they pre-registered accordingly. Additional we double-checked with European Chemical Agency ECHA and found that for all metals used in our processes pre-registration took place.

After pre-registration period ending ECHA will publish until 1^st January 2009 a list of all pre-registered substances on their web-site. Listed will be the naming of the substance, the EINECS- or CAS-number and the previewed registration deadline. Names of pre-registrants will not be issued, but are available to authorities.

Metals which are subject of imports from Non-EU-countries we pre-registered according to regulation. Here we are defined as importer and therefore under obligation to register these metals.

All pre-registered metals from our production program now have a transition period until 30^th November 2010 for final registration. We will make sure that our suppliers register in time. As a safety measure Schlenk Metallfolien has pre-registered all relevant metals additional.

Metals pre-registered are:

Metal	EINECS-No.	CAS-No.
Copper	231-159-6	7440-50-8
Zinc	231-175-3	7440-66-6
Tin	231-141-8	7440-31-5
Nickel	231-111-4	7440-02-0
Silver	231-131-3	7440-22-4
Iron	231-096-4	7439-89-6
Lead	231-100-4	7439-92-1
Chromium	231-157-5	7440-47-3
Aluminium	231-072-3	7429-90-5
Magnesium	231-104-6	7439-95-4
Manganese	231-105-1	7439-96-5
Phosphorus	231-768-7	7723-14-0
Silicon	231-130-8	7440-21-3

(metals, pre-registered but not mentioned, are part of our material development)


Information in the supply chain

According to Annex IV (communication in the supply chain) and Annex V (downstream users) we are obliged to submit to our metal suppliers the application and exposure information for the products supplied to our customers. As user of our products you are defined as downstream user as well. (Exceptions are private persons and craft shops). We will contact you in due course to inquire information regarding application and/or the respective use of our products in your processes. In case you have this information available due to your own REACH activities already it would be helpful to us if you submit the info in advance (by electronic file or on paper). Thank you in advance for your support.

Candidate list-list of substances subject to authorisation (Annex XIV REACH regulation)

Substances of Very High Concern (SVHC) are subject to authorisation under the REACH regulation.

In October 2008, the European Chemicals Agency (ECHA) published on Internet the first candidate list, in January 2010 list number 2 and in June 2010 list number3, each with substances of very high concern (SVHC) for inclusion in Annex XIV of REACH-regulation:

Details regarding substances concerned please find in

candidate list file

Substances mentioned in the candidate list 1 and 2 are not included in our products.

Referring to current legislation we point out that metals used in our company do not meet further criteria in Article 57 (example: CMR cat. 1 and 2 ; CMR=substances being carcinogenic, mutagenic, toxic to reproduction) for inclusion in Annex XIV of REACH regulation.

Additional info IMDS-system of automotive industry:

Among others, the IMDS-system of automotive industry is instrument to inform customers regarding substances of very high concern (SVHC).

Information is requisite if content of these substances in a product is >0.1%.

Automotive industry pointed out that the SVHC refer to constituents of components only, but not to manufacturing processes.

Miscellaneous

We ask your understanding that, due to the complexity of measures we have to take fulfilling the REACH-regulation, we will not answer to individual questionnaires.

We keep you updated regarding the implementation of REACH at Schlenk Metallfolien GmbH & Co. KG. Your known contact persons inside our sales department will further on try to be of help in case of upcoming questions regarding REACH.