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REACH Declaration requirements for Mechanical Components

Q

qalsang

#1
Hi

We are supplying some mechanical assemblies for our Europe customer.

Our assemblies include rubber, steel shafts , c-clip and some plastic
components.

I understand that I would need information on the rubber & plastic
components but Is it necessary for me to get REACH declaration on SVHC
material for components such as steel shafts , clip & other 'hard components??
 
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S

SteveK

#2
Re: REACH Declaration for Mechanical Components

Hi

We are supplying some mechanical assemblies for our Europe customer.

Our assemblies include rubber, steel shafts , c-clip and some plastic
components.

I understand that I would need information on the rubber & plastic
components but Is it necessary for me to get REACH declaration on SVHC
material for components such as steel shafts , clip & other 'hard components??
As you are not a primary manufacturer (like my company) you do not have any direct registration obligations under REACH. However, it is advisable that you can supply a statement on SVHCs that are in a particular component that you have identified. In one of our products we have phthalates, which are covered by SVHCs. Thus I have a letter; which I guess is a type of declaration, which I can supply to customers (see attached).

I hope this helps.

Steve
 

Attachments

T

TamTom

#3
Re: REACH Declaration for Mechanical Components

Hi

We are supplying some mechanical assemblies for our Europe customer.

Our assemblies include rubber, steel shafts , c-clip and some plastic
components.

I understand that I would need information on the rubber & plastic
components but Is it necessary for me to get REACH declaration on SVHC
material for components such as steel shafts , clip & other 'hard components??
Hello,

First I agree with Steve, and keep two things in mind:

All material (mostly) is covered by REACH

but you must declare it if you deliver the material above a ton a year.
(That's not correct this way, because if you outside EU you should'nt declare anything, then your customer works as an importer and must declare the stuff from the legal side, but he is the customer:biglaugh:)


Regards,

TamTom
 
Last edited by a moderator:
Q

Qualityjules

#4
Re: REACH Declaration for Mechanical Components

Also note that the SVHC's must be released under normal operation of your product. For example we make products out of steel, the steel may have lead, but under normal use of the steel product there is not planned exposure to humans or environment (even though lead is a exemption as an alloying metal in steel, used for example only). I am attaching a sample REACh declaration
 

Attachments

chris1price

Trusted Information Resource
#5
Hi

The REACH guidance documents says:

"Suppliers of an article containing a substance that appears on the Candidate List in a concentration above 0.1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of the substance (Article 33). This applies when the article is supplied to recipients who are to use it as part of their work."

"Equivalent information should be supplied to consumers (the general public) if it is requested. The supplier has the duty to provide this information within 45 days of receipt of this request."


If I supply an article which contains DEHP to a hospital, do I have to notify them when I sell the product, or can I wait until they request it? What if it is supplied to a commercial company?

Chris
 
B

Balu Sharma

#6
I think you can wait till the customer requests the information.

Article 33.2 says that...
 
L

LLIMA

#7
Dear all.

I´m involved with automotive industry (tier one) for ceramics components (our final component is a ceramic part, done by ourselves base in a mixture of several chemical components). Do we need to use (apply) IMDS or REACH database for no forbidden substance declaration?

Regards
 
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