26th October 2010
REACHDear Sir / Madam,
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Re: REACH Compliance |
1. 2010 registration deadline
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Indestructible Paint, as a supplier of coatings, recognises the role that we have under REACH as a downstream user. We recognise that the regulation places a heavy burden of communication within the supply chain and poses a threat to any business operating within the European Union.
Due to the complexity of our supply chain we are finding it impossible to track every chemical component used in our coatings. We are working on a weekly basis with our supply chain and using the data available from ECHA to ensure that we are compliant with the REACH legislation and to avoid any continuity of supply issues.
The severity of the threat to business in Europe is summarised by Caroline Spelman, Secretary of State DEFRA and Rt Hon Vince Cable, Secretary of State Business in their letter to the European Commissioners. (For the text please see the attached PDF left.)
Indestructible Paint is working diligently to maintain our continuity of supply. If the continuity of supply for one or more of our products is threatened for any reason, all affected customers will be notified immediately.
In response to our obligations under the regulation and enquiries from our customers, Indestructible Paint can confirm the following:
1. 2010 registration deadline
Indestructible Paint recognises that the 2010 chemical registration deadline is a potential threat to our and our customer’s business continuity.
Indestructible Paint is not intending to delete any products / product ranges due to the 2010 registration deadline. We have a close liaison with our Raw Material supplier base who assures us that there is no intention to discontinue any of our raw materials due to the 2010 deadline.
At Indestructible Paint we identified that we use in the region of 500 individual raw materials. Evaluation of the MSDS data for these materials identifies 1000+ chemical components. Within our capabilities we are monitoring the data issued by ECHA to ensure that the chemicals we identified within our raw material supplies meet the required registration deadlines.
Details of the current SVHC list can be found at: current SVHC list
2. SVHC notification
Indestructible Paint does not use any of the SVHC’s listed on the current Candidate List of Substances of Very High Concern for authorisation updated 18/06/2010.
Indestructible Paint is aware that proposals are in place to add further chemicals to the SVHC list in 2011. If any user of Indestructible Paint coatings is concerned with the implications of the revisions to the SVHC list, please send an e-mail to the REACH co-ordinator or sales department specifying the Indestructible Paint code for the coating in question.
Compliance with REACH is an integral part of our business at Indestructible. We will work closely with our customers to ensure a sustained supply of products and to develop the future generation of coating solutions.
If you wish to discuss this matter or require additional information, the REACH co-ordinator for Indestructible Paint is:
Richard Banks Tel: 0121 702 1517 e-mail: richard@indestructible.co.uk
For MSDS updates our contact is:
Sue Harris Tel: 0121 702 1501 e-mail: sue@indestructible.co.uk
Yours faithfully
For and on behalf of Indestructible Paint Ltd.
Richard Banks
Project Chemist
