REACH COMPLIANCE NOTIFICATION
Registration, Evaluation, and Authorization of Chemicals
As a Manufacturer, Importer, and Downstream user to the European Union (EU), Jet-Lube, Inc. is familiar with the European “Registration, Evaluation, and Authorisation of Chemicals” (REACH) regulation (1907/2006/EC), including the timetable for substance pre-registration and registration. We recognise that the regulation imposes obligations on manufacturers, importers and downstream users in the EU and globally. We also realise that in order to effectively implement the regulation, joint collaboration across all supply chains, including sharing information, is necessary.
We are pleased, therefore, to be able to confirm the following:
Jet-Lube has verified with all our upstream suppliers that all substances that are subject to REACH have now been successfully pre-registered with the European Chemicals Agency in Helsinki (ECHA).
Where there are any exceptions to this, Jet-Lube, Inc. have submitted our own pre-registrations to ECHA through our Only Representative, Jet-Lube (UK) Ltd.
As we now enter the Registration phase of REACH, we are required to advise the registrant of each substance of downstream uses. We will be contacting all our customers in the near future to obtain the necessary downstream information required for Jet-Lube to represent your and your customers’ uses required for the full registration of these substances.
In accordance with Annex XV of REACH - Substances of Very High Concern (SVHC), Jet-Lube, Inc. has reviewed our products with regard to the 15 SVHC substances included in the ECHA candidate list published on 28 October 2008. Based on our current knowledge and available information (such as safety data sheets [SDSs]) provided to Jet-Lube by our suppliers, we do not believe that any of our products contain any of the 15 SVHC substances at levels greater than the tolerated maximum concentration values established by the EU Regulation 1907/2006/EC, or above 0.1%, whichever is the lower.
Unfortunately we are unable to provide pre-registration numbers for substances; it is not required under the REACH regulation to provide downstream users with this information and, therefore, where the manufacturer of the substance has completed the pre-registration it is not obliged to disclose this information.