European Union Regulation No.1907/2006 (REACH)
Late in 2006 European legislation aimed at controlling chemical substances produced and supplied within the EU was published. We can confirm that West & Senior Limited will comply with the requirements of the Reach Regulation EU No.1907/2006. It is essential that the substances we use in our products that come within the scope of the REACH regulation are pre-registered by the 1st December 2008 with a transition period of between 3 and 11 years dependant on volumes. To this end, we have contacted all of the suppliers of substances used in our products that require pre-registration and eventual registration under the umbrella of REACH legislation. This process is now complete. It must be noted that it is not a legal requirement of REACH to divulge the exact pre-registration numbers from our suppliers. We only need to confirm to the downstream users of our products that pre-registration of substances contained therein has been done where necessary. Please be assured that West and Senior Ltd is in the process of evaluating commercially supplied formulated products, both from a supplier and down stream customer end use. This will involve ongoing dialogue with our Suppliers and Customers over the coming months. To see a typical document used in this process, please follow this link: REACH: Standard Questionnaire for Communication along the Supply Chain.
REACH is very much an evolving and ongoing process, however if you have any concerns regarding the implementation of this regulation and West & Senior products please do not hesitate to contact us at firstname.lastname@example.org
For your information please see below technical guidance notes with regard to product definitions.
Technical Notes on REACH interpretation in relation to products supplied by West and Senior
It must be noted that we are manufacturers of Pigment and Additive dispersions/mixtures for the Polymer Industries. These are mixtures and preparations which intrinsically do not involve chemical reactions and as such, in themselves do not need to be registered within REACH. It is, however, our responsibility to ensure that the manufacturers and suppliers register the component parts where required.
Please see the clear definitions of mixtures and preparations below:-
Extract from:- "Technical Guidance Document for identification and naming of substances in REACH." "According to Article 1 of REACH, the Regulation concerns the manufacture, import, placing on the market and use of substances on their own and in preparations and articles. Preparations and Articles as such are not regulated in REACH."
A preparation is referred to as a mixture in the GHS. (Globally Harmonised System of classification and labelling of chemicals). The definitive meaning of mixture & preparation in GHS is:- "Mixture means a mixture or solution of two or more substances which do not react (Mixture and preparation are synonymous)"
S R Senior