REACH: contradictory statement from supplier?

zork_14

Starting to get Involved
#1
Hi,

a large company has provided me a REACH statement for a product. The statement in my eyes does not make sense.

One part states (my bold highlighting):

"XXX Inc.’s hereby declares the object(s) of this declaration do not contain the substances listed in the following sections of the directive
Substances of Very High Concern as defined in Article 59 annex X with all amendments up to and including July 8, 2021."

Followed by a table that reads:

"Part Number: XXX"
"Part Description: XXX"
"REACH COMPLIANT: NO (SVHC Lead)"

Is it contradictory or am I missing something?

Thanks
 
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Ninja

Looking for Reality
Trusted Information Resource
#2
Looks like an oops with boilerplate forms. Have you gone back to the person who sent it to you and asked?
 

zork_14

Starting to get Involved
#3
Thanks @Ninja. Yes, I just got a reply: "I apologize, I know it can be confusing. That is our standard writing but if we state that it is not compliant on the item itself, then it is not compliant. ".

I take that this item is then probably not compliant, but there is still a doubt that it might be a simple copy/paste error because this person has no idea about what they are doing.
 

Ninja

Looking for Reality
Trusted Information Resource
#4
"REACH COMPLIANT: NO (SVHC Lead)"
Fair enough...but knowledgeable or no, true or no...it will be pretty hard for you to defend with that in writing in your hand.

Always safer to get something unambiguous to rely on. That word "probably" keeps lawyers and engineers up at night...
 

mattador78

Quite Involved in Discussions
#5
REACH is a huge pain in my backside as the whole thing is just messy, there are products which are SVHC which are banned but which then can continue to be used dependent upon the end user or application Hexavalent chrome being a prime example.
 
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