The European Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) came into force on 1 June, 2007 and is designed to consolidate various pieces of chemical legislation within Europe and improve the level of information available within the supply chain on chemicals.
The main obligation under REACH is to register any “substance” manufactured in or imported into the European Union in quantities of more than 1 ton per year. A substance is defined as “any chemical element and its compounds in the natural state of obtained by any manufacturing process”.
We do not manufacture or import any “substances” and no substances are intended to be released from our products under normal and reasonably foreseeable condition of use. Therefore we have no registration obligations under REACH.
We do however produce “articles” for the purposes of REACH, which are objects which during production are given “a special shape, surface or design which determines its function to a greater degree that does its chemical composition”. For example, our laminate and pre-preg products are classed as articles under this legislation.
Manufacturers of articles do still have some obligations under REACH, particularly where the products contain listed “Substances of Very High Concern”.
For example, where a product contains a listed substance in a concentration above 0.1% weight by weight a supplier must provide customers with sufficient information to allow them to use that product safely. In certain circumstances a notification must also be made to the European Chemicals Agency (ECHA).
The Substances of Very High Concern are set out on a list prepared by the European Chemicals Agency known as the Candidate List which is updated from time to time. At the time of writing this list contains 84 substances – the up to date position can be viewed at ECHA.
We can confirm that, to the best of our knowledge, none of our products contain any of the substances currently listed on the Candidate List at concentrations >0.1% and therefore that we have no formal obligation to supply information to our customers or consumers or to make any notification to the European Chemicals Agency.
However, as we are committed to ensuring environmental compliance and sustainability globally we will continue to monitor any changes to the REACH legislation and, in particular, the development of the Candidate List and will review this position regularly to ensure continued compliance.
If you require any further information on the impact of REACH on our products please click here.