Service Part Issues - Request for MDS and REACH Declaration

P

polly40

#1
A couple of questions specific to service parts if someone can kindly help :-
1) Our service parts got to a logistics centre, not the OEM. As such, this is a different company to where the mass production parts were originally supplied (same parent company). We are now getting requests for MDS from the logistics centre, these have already been registered for mass production supply but they are pushing that they require resubmission of all part numbers as they are a different company code. Is this normal procedure or does one submission per part number suffice ?
2) We are also getting MDS and reach requests from the service centre for service parts that were supplied previously, some as far back as 1999. It would be virtually impossible to get MDS data for these parts. I cannot find any clear ruling on this but common sense suggests parts manufactured before the legislation came into place have to be exempt ?
3) If we have to now manufacture a new batch of service parts that were mass production in 1999 using the same materials and methods, would we have to make MDS or reach declaration for this new run of service parts ?

Our customer seems to be as ill informed as we are on this one, they insist they will apply all new legislation retrospectively, therefore parts on the shelf now could be illegal to sell in five years time ! This cannot be correct ?

Many TIA
 
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Kales Veggie

People: The Vital Few
#3
1) General rule is that each of your customer needs an MDS submission for each parts. Information in IMDS is not shared between customers. MDS information for one part can be easily send to multiple customers through the "propose" option
2) REACh does not have a grandfather clause. Product sold on the market today must meet the requirements of today. (and not when it was produced, to prevent stockpiling for example)
3) Yes, if you have not made a submission before. Your customer has rules about when a resubmission is required (e.g. part number change, weight / chemical change, supplier change). Unlikely that parts produced in 1999 will be exactly the same as today.
 
I

imdsforum

#4
Thank you Kales, not the answers I was wanting or expecting but at least I know where we stand.
 
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