Dear Sir or Madam,
In December 2006 the European Parliament and the Council adopted the new Regulation concerning Registration, Evaluation and Authorisation of Chemicals, titled REACH (EC) No 1907/2006. The most important elements of REACH are a uniform testing procedure for the registration of existing and new substances and a chemical safety assessment for the use of these substances. The schedule for the implementation of this regulation is based on the volumes produced or imported and on the hazardous properties of the substances:
- Phase-In, Pre-registration: June 01 – Nov 30, 2008
- Phase 1, Registration of substances ≥1000 to or ≥100 to labeled R50/53 or ≥1 to labeled as cmr (carcinogenic, mutagenic, reprotoxic): Dec 01 – Nov 30, 2010
- Phase 2, Registration of substances 100 – 1000 to: Dec 01, 2010 – May 31, 2013
- Phase 3, Registration of substances 1 – 100 to: June 01, 2013 – May 31, 2018
What does this mean for Pulcra Chemicals products?
Pulcra Chemicals pre-registered all substances produced or imported on time. Substances produced or imported after Nov 30th, 2008 could be late pre-registered until 12 months before the specific deadline. We used and use this option. We got submission reports and pre-registration numbers from ECHA (European Chemicals Agency) which documents the acceptances of the pre-registrations.
We would like to inform you that Pulcra Chemicals GmbH decided not to communicate any pre-registration numbers, because the pre-registration numbers have a legal relevance only for the registrant.
Pulcra Chemicals GmbH confirms that all substances and/or the monomers used for the polymer components, which are ingredients of the following product/the following products, were pre-registered according to REACH – unless they are exempted from registration - by our company or should have been registered by our suppliers and that the substances due to registration by Pulcra Chemicals in phase 1 and 2 really were registered.
Moreover, we confirm that substances listed in the Candidate List of Substances of Very High Concern (SVHC) as issued by the ECHA on 20 June 2013 are not intended components with > 0.1% of our above named product's composition. This statement exhibits our current state of knowledge. If you may have any further questions, please do not hesitate to get in touch with us again.