Regulatory

Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)

January 20, 2009

At the end of 2006, the regulation for the Registration, Evaluation, Authorization and Restriction of Chemicals (REACh) was published as EC-Regulation 1907/2006.  REACh has entered into force on June 1st, 2007.  The first crucial phase under REACh was the pre-registration of all substances within a six month period that ended on December 1, 2008.

The pre-registration of substances is a condition that will enable companies to use the transition period between pre-registration and registration to continue their business without interruption.  Depending on substance character and volumes, the transition period will last from 3 to 11 years starting on December 1, 2008.

Penn Color has been in close contact with its suppliers, executed all necessary actions to complete the pre-registrations for the substances currently introduced into the European Community either by direct imports or by local production.

This means that products directly sold into, or manufactured in the European Community are REACh compliant according to the three specific criteria listed below.  This is only a statement of compliance during the REACH Phase-in period (the period between pre-registration and statutorily required registration date for a specific substance).

Specific criteria:

  • Substances in a given product are either pre-registered by our OR, or by our vendor’s OR.
  • Substances in a given product are either pre-registered or are exempt from pre-registration.
  • Substances in a given product are a combination of 1 & 2 above and other substances may be under the 1 metric ton threshold.

As the Phase-in period for a substance is volume dependent, it is necessary to keep track of the volumes imported into the European Community. You may already know that registration must contain information on exposures and risks in downstream uses of substances and preparations.  As such, we may require information from our customers to ensure that the substances used in our products are properly registered.  It is quite evident that a mutual exchange of information on use and importation into the European Community will be necessary.  Therefore, we will continue communicating with our customers regarding these matters.

Please know that we understand our customers’ concerns related to the registration process and we assure you that we will work closely with our customers in complying with this directive.  As a further measure to support our customers, Penn Color will periodically update the information on this site. You may also use the following e-mail link (reach@penncolor.com) to submit requests for additional information directly from one of our REACH Coordinators.

If you have any additional questions or concerns do not hesitate to contact us on this matter.

Sincerely,

Michael Rubeo
EHS Manager and REACH Coordinator