Declaration of conformity on the REACH regulation


Dear business partner,

The new European Chemicals Regulation (EG No. 1907/2006) for registration, evaluation, approval and limitation of chemical substances (REACh) took effect of July 7, 2007.

Therefore since June 2008 substances with more than one ton per year shall not be produced in the EU or imported in to the EU, if they have not been preregistered or registered.

In accordance with article 2 waste materials subject to the directive 2006/12/EWG are not being regarded as substances, preparations or products in terms of article 3 of the REACh regulation.

Therefore there is no obligation to register or authorize waste material; there is also no obligation to inform about the material.

According to REACh the production of substances from waste, so-called secondary raw materials, is fundamentally classed as a production subject to registration.

Therefore also recycling companies are subject to registration according to article 6 of REACh.

According to article2 (7d) substances that have been recycled within the EU are exempt from this registration, if they are identical with substances that have already been registered and if they are at the recyclers disposal (according to article 31: material safety data sheet and article 32; information without safety data sheet).

Polymers are not subject to registration. However, according to article 6, monomers with respective polymers built on have to be registered.

Additive polymers (compounds) are rated as a preparation, which substances (plasticizers, filler and reinforcing material, as well as dyes) have to be registered.

Under the policy of “Maintaining the stability of polymers” (§ 3), all additives maintaining the stability of a polymer (e.g. antioxidants) are covered by the substance definition.

In terms of communication according to § 31 we have noted that by today we have no information from our suppliers, that would require notification of any substances marked in the list of candidates ( attachment XIV, REACh-regulation).

As this list is being modified continuously, we refer our explanation to substances listed so far.

As the final registration of monomers and additives is being carried out by producers and importers of the primary substances, there is no need for us to perform our own registration of any of the substances.

In addition, as being traders in compliance with the REACh regulation, we are classed as a downstream user and therefore not obliged to preliminary or final registrations.

Wherever necessary we have requested a confirmation from our customers that the preliminary registration of monomers and additives has taken place.