Response to Enquiries and Questionnaires Regarding REACH
EC Regulation 1907/2006 Concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).
REACH Enforcement Regulations 2008
The regulations require all ‘substances’, which includes all metals, to be registered under REACH. It is important, however, to note that REACH Regulations distinguish between ‘substances’ and ‘preparations’ (which are covered by REACH) and ‘articles’ (which are not governed by REACH and do not require registration).
The Company’s standard semi-finished products in aluminium, aluminium alloys, stainless steel and copper alloys such as sheet, plate, tube, bar and extrusions, are all classed as ‘articles’ and do not need to be registered. Billets, blooms, concast slabs and machined ingots are all also classed as ‘articles’ and do not need to be registered. However, certain types of ingots such as ‘as cast’ ingots, rolling ingots and ingots produced for extrusion processes, are classed as ‘preparations’ and would, therefore, need to be registered.
For the reasons stated, The Company can confirm that products supplied to you from its standard range are classified as ‘articles’ and therefore do not need to be registered under REACH.
A copy of the production diagrams for aluminium and stainless steel is available on request, to help clarify the definitions of ‘substances’, ‘preparations’ and ‘articles’.
Due diligence has been carried out on The Company’s current supplier base to establish that ‘substances’ and ‘preparations’ which require registration under REACH have been registered or confirm the absence of such chemicals. For this reason, as far as reasonably practicable, The Company can confirm that the majority of its standard semi-finished products detailed above, do not contain any of the chemicals listed in the current Candidate List of Substances of Very High Concern (SVHC) January 2019.
The only exception to compliance is where a grade of material is ordered by a customer where the British, European or International Standard covering the grade requires a deliberate addition of one or more of the substances in order to comply with the standard/grade requirements. In this case, the material will contain a value of each substance in line with the standard requirements.
It is possible that you may purchase other products or metal types from The Company that are outside of its normal stock range. In these circumstances, The Company would need to check with the producer that these specific products do not contain any of the listed Substances of Very High Concern and advise you accordingly.
The Company trusts that this information clarifies its position regarding compliance with the REACH Regulations. If you have any questions or want to check on any specific product that you are unsure about, please contact The Company.
This Policy will be updated on amendments to the legislation and as a minimum annually.