REACH Regulation (EC) no. 1907/2006
The REACH Regulation EC 1907/2006 has been in force since 01.06.2007. This regulation doesn't just contain obligations for manufacturers and importers of substances, but also for their “downstream users in the supply chain”.
The downstream users must ensure that information is passed on to suppliers and customers and that a material safety report is produced if required.
Any substances not pre-registered may no longer be imported, manufactured or sold after 01.12.2008. This also applies to products or preparations containing these substances.
In other words, REACH applies to any kind of product and isn't restricted to chemicals.
Do you supply ProMinent GmbH?
Supplier information relating to REACH
In our role as a “downstream user”, we require our suppliers to:
- Ensure that all substances contained in products supplied to us and requiring registration are pre-registered/registered. This must be handled by yourself, your suppliers, manufacturers or importers.
- Ensure the ability to supply in compliance with REACH requirements. Please once again note compliance with the registration deadlines (Art. 5: no data, no market).
- Within your company, take all organisational measures that are needed to implement the REACH Regulation. This includes appointing an exclusive agent in the EU, if you, the manufacturer, are not based in the EU.
- Immediately inform us if any products supplied to us and containing substances according to Art. 57/59 cannot be registered.
- Send us safety data sheets containing the further data required by REACH for all chemicals/preparations supplied to us in a digital form (firstname.lastname@example.org) as soon as this data is available (exposure scenarios!) and agree on intended use with us if necessary.
- In accordance with the candidate list (Art. 59) and information from your upstream actors, immediately inform us of the substances included in the supplied products according to Art. 57 and therefore fulfil your duty to inform (Art. 33). In accordance with REACH requirements, we expect our suppliers to provide us with details of the substance names, registration numbers (until known, the CAS/EC numbers) and the respective percentages by weight in the supplied product and/or supplied product component .
ProMinent GmbH in its role as a manufacturer
Products labelled as “Operating chemicals/chemical additives”
Information relating to all chemical substances within the supply chain, i.e. starting with the manufacturer or importer, then the processor and intermediary and ending with the seller, must be passed from one link in the chain to the next. This applies especially to the information needed to ensure safe use of the substance. For the most dangerous substances, this information is passed on in a standardised form using what are known as safety data sheets.
You will find the safety data sheets for our products at the Download area if you filter by "Safety data sheet" document type. The safety data sheets are available for various countries and in various languages.
All other products
Substances in products: In accordance with REACH, a product is an object, which during manufacture takes on a specific form, surface or shape, which determines its function to a greater extent than its chemical composition. If a product contains a concentration of more than 0.1 percentage by weight of a particularly alarming substance, then this information must be passed from every supplier to every purchaser along the supply chain. On request, consumers must also be informed of the presence of this substance.
It’s not just chemical products that are covered by the REACH Regulation, but also devices, pumps, sensors, fittings, controllers and many other elements of our product range. ProMinent GmbH will communicate details of substances from the candidate list contained in its products to the best of its knowledge. ProMinent GmbH is hugely reliant on its upstream suppliers to pass on this information.
In practice, ProMinent’s B2B customers (downstream users) are proactively informed if products contain substances from the candidate list above the approved limit values, as required by the directive.
An overview of substances from the candidate list can be found here: https://www.reach-info.de/kandidatenliste.htm . This list is dynamic. All EU countries can apply to the ECHA for new substances to be checked for inclusion in this list.
Information about substances from the candidate list in our products
REACH Information - Latest (as of October 2019):
The current Candidate List, that is the list of substances of very high concern for authorisation (in accordance with Article 59 (1, 10) of Ordinance (EC) No. 1907/2006 (REACH)), can be found here: https://www.reach-info.de/kandidatenliste.htm
Lead (Pb) (CAS 7439-92-1, EC 231-100-4)
Many of the standard items we supply contain components made from steel, aluminium or copper compounds containing lead, a substance on the current Candidate List, in concentrations of more than 0.1 mass percent. The exemptions under the Restriction of Hazardous Substances Directive (RoHS) can be availed of as follows:
- Lead as an alloying element in steel (currently exemption 6a in Appendix III of the RoHS Directive) for machining purposes and in hot dip galvanised steel containing up to 0.35 % lead by weight, in categories 1 to 7 and 10.
- Lead as an alloying element in aluminium (currently exemption 6b in Appendix III of the RoHS Directive) for use with a content of up to 0.4% lead by weight, in categories 1 to 7 and 10 (the exemption period varies according to the form of aluminium alloys).
- Lead as an alloying element in copper (currently exemption 6c in Appendix III of the RoHS Directive) for use with a content of up to 4% lead by weight, in categories 1 to 7 and 10.
Bisphenol A (BPA) (CAS 80-05-7, EG 201-245-8)
Currently a concentration of more than 0.1% by weight of Bisphenol A is to be found in an electrical component of our Signal pump. Only product range S1Cb is affected. We are urgently working to try and procure this component free of harmful substances. You’ll find detailed information on this memo here: email@example.com
Further information about this matter
You can find information about the REACH Regulation online on sites including: