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on the subject of REACH directive

The REACH system is based on the principle of iindustry's individual responsibility. Following the rule of "no data, no market", only those chemicals are allowed to be marketed within the territory covered by this directive which were registered before. Each manufacturer or importer who wishes to market his materials which fall under the rule of REACH must possess an individual registration code for these products. One year after REACH comes into force, the current legislation will continue to remain valid. After that time ECHA, an agency in Helsinki, should be fully operational. ECHA will mainly take over the organisation and control within the REACH process.


At the same time, on June 1, 2008, the six-monthly pre-registration period for certain substances commenced. The pre-registration process is slotted in ahead of the actual registration. Its purpose is the establishment of forums within which various manufacturers and importers of identical substances can exchange views. In return, manufacturers/importers are granted extended registration deadlines depending on the type and quantities of the substances in question if they take part in the pre-registration process which is free of charge.




The paint and lacquer materials produced by our company are formulations, not genuine chemical substances: The registration deadlines and requirements in accordance with REACH apply to original substances only. As a manufacturer of paints and lacquers, and thus a subsequent ("downstream") user, no REACH pre-registration is intended for our company.


According to the REACH terminology, manufacturers of paints and lacquers who do not produce or import their own materials are, as a rule, so-called "downstream users" and do not need to register themselves but are definitely affected by REACH. On the one hand, the formulations which they work with have to include information as to what registered substances (> 1 tonne/year) are contained in each one of these. Furthermore, according to art. 31 to 36 of the directive, information has to be passed down the complete supply chain to ensure that the use of that particular chemical material is safe for both human health and the environment. Rights and duties of downstream users are laid down in art. 37 to 39.


As a downstream user, we want to be certain that the necessary base substances for the formulations of the paints and lacquers supplied to you is available in the long term, too. For that reason, we have already asked our suppliers of these materials whether they intend to have their substances registered. Our sub-suppliers have assured us that all products currently used by us have been pre-registered.


This means that, with the information available at present, we will be able to supply you in future with the current coating products in the quality you are used to. We will inform you immediately about any changes in the information we have.


As soon as the provisions and regulations pertaining to REACH finally come into force and become effective, we will change the designation. for example in EU safety data sheets, to conforrm to REACH.





p.p. T. Di Filippo / January, 2009