Customer information – "REACH"
What is REACH?
REACH is the abbreviation for Registration, Evaluation, Authorisation (release) and restriction of
Chemicals and stands for a new law on chemicals within the EU.
The core aspects are as follows:
- Clear regulation of the registration and approval of "chemicals"
All "substances" (chemicals) manufactured / imported in quantities of one tonne
per year or more must be registered by the manufacturers / importers.
The substances must be exclusively registered with the European Chemicals
Agency (EchA).
- Reversal of the burden of proof to the manufacturer of "chemicals"
The manufacturer must "actively" inform its customers about the use of
"questionable substances“ within the meaning of REACH, and/or offer
alternatives.
This means that Rittal must also be "actively" informed by its suppliers and
Rittal must "actively" inform its customers afterwards.
- No data - no market (no registration – no marketing)
What does this mean for Rittal?
-
Rittal neither manufactures substances / preparations nor imports them from
outside the EU. The only exceptions are preparations (touch-up sticks, paint,
sprays etc.) which Rittal places on the market as dealer. The relevant safety data
sheets of these preparations are stored on the Internet and are available for
download. We would ask you to compare the applications indicated in the
relevant safety data sheets with your choice for their intended use, and to inform
us immediately in case of deviations.
-
With regard to the manufacture, Rittal is only "downstream user"
(e.g. cleaning, painting of components). This means that we use different
chemicals for the manufacture of our products.
Our products are manufactured items and not substances / preparations within
the meaning of REACH, and they do not release such substances / preparations
during their application.
Therefore, the registration obligation does not apply to our products.
What are our activities?
-
Rittal maintains contact with the manufacturers of substances / preparations to
verify whether the Rittal application is known to the manufacturer and the
substances have been registered and/or preparations will be registered
(complete registration takes place until 2018).
-
Rittal has included all currently known substances which "give cause for concern"
(SVHC list) into existing technical delivery conditions (AA-TL-035 "List of banned
substances and declaration list“). These technical delivery conditions contain all
currently valid international regulations and laws that are applicable to our
products as well as our customers' lists of banned substances, and they are
continuously reviewed. All suppliers of Rittal are required to provide a binding
confirmation that the aforementioned technical delivery conditions are complied
with. Up to now, all feedback has been negative. Therefore, no information about
the use of substances indicated in the SVHC list has been made available to us.
With regard to all new parts, compliance with the technical delivery conditions is
checked as essential part of the release within the scope of sampling.
-
Additionally, we perform chemical analyses of selected materials / components
on a random basis. Thus, we additionally check whether our requirements are
complied with.
Based on the aforementioned information and activities, there are currently no
indications that substances are used which are prohibited within the scope of REACH or
any other legal provisions and/or according to our technical delivery conditions.
If, however, our examinations and/or any information provided by our suppliers indicate
the use of banned substances, we will immediately check alternatives and actively
inform you as our customers.
This means that our products as well as any preparations which we place on the market
as dealer comply with the requirements of REACH according to the current state of
knowledge.
Should your inquiry about banned substances refer to substances other than those
included in our technical delivery conditions, we will review these substances within the
scope of our regular updates and included them into our list, if applicable.
For this reason, we ask for your understanding that we are unable to provide you with
individual confirmations regarding the substances in products.
Herborn, November 2009
Rittal GmbH & Co. KG
Quality Management
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