IMCD REACH-team
- IMCD has a central REACH implementation team of highly skilled REACH experts, chaired by the IMCD HSEQ coordinator and supported by the IMCD top management
- IMCD has a state-of-the-art central REACH database
- IMCD actively participates in stakeholder organizations (FECC)
- IMCD has extensive experience with regards to the handling of chemicals as the link between manufacturers and downstream users
IMCD service to our customers
- IMCD REACH experts support the IMCD sales team/customers with all REACH aspects
- IMCD ensures full REACH compliance
- IMCD REACH experts offer assistance in understanding extended-SDS’s
- IMCD ensures full communication in supply chain
- IMCD REACH experts ensure the full REACH compliance of imported substances
IMCD service to our suppliers
- IMCD REACH experts support the REACH communication between IMCD product managers and suppliers in all aspects
- IMCD assures full REACH related assistance regarding downstream uses
- IMCD ensures full communication in supply chain
- IMCD ensures compliance assistance regarding imported substances for non-EU suppliers
IMCD DECLARATION OF REACH COMPLIANCE
In order to conform to REACH, IMCD recognizes that downstream users will need to have assurance that all the products IMCD distributes are in full compliance with REACH.
IMCD states hereby that all products IMCD supplies are checked, according to the REACH regulation, to ensure compliance with this regulation. At least one of the following conditions is met:
- Substance(s) or substance(s) in mixtures are (pre-) registered by the EU supplier.
- Substance(s) or substance(s) in mixtures are (pre-) registered by the OR of a non EU IMCD supplier.
- Substance(s) or substance(s) in mixtures are exempt from REACH according to ANNEXE IV or V
- Substance(s) or substance(s) in mixtures are supplied by IMCD in quantities less than 1 t/year and do not require REACH (pre)-registration.
IMCD is prepared to issue a REACH compliance statement for each product IMCD sells or send the relevant REACH statement of its supplier.
SUBSTANCES OF VERY HIGH CONCERN (SVHC)
According to Article 31 of the REACH Regulation, from the date of inclusion of any substance in the Candidate List, suppliers have to provide their customers with a Material Safety Datasheet (MSDS).
Consequently if IMCD supplies SVHC substances or mixtures that contain SVHC substances, IMCD shall communicate their presence in the products through the required MSDS.
Furthermore suppliers of mixtures not classified as dangerous according to the preparation directive and CLP regulation have to provide the recipients at their request with an MSDS, if the preparations contain at least one substance on the Candidate List and its individual concentration is at least 0.1% (w/w) for non gaseous preparations and at least 0.2% by volume for gaseous preparations.
IMCD is also aware of the 45 day limit that suppliers of articles have to respond to similar enquiries (Article 33). IMCD ensures that the SHVC information will be transmitted from our supplier/manufacturer to our customers.
Extended SDS and USE DESCRIPTION SYSTEM
The extended SDS details exposure scenarios, risk management measures and operational conditions that need to be followed by the downstream users and in most cases will state the uses utilizing the ECHA’s Use Descriptor System.
Any extended SDS (where applicable) shall be made available by IMCD’s suppliers, through IMCD, to all its customers.
Upon receipt of the uses stated in the extended SDS, the IMCD customer, being the downstream user, is responsible to verify that their uses are included in the extended SDS. If this is the case no further action from the downstream user is needed. On the other hand, if a use is missing, the downstream user is well advised to apply his right to make his use known.
It is also important to note that there are several reasons why an Exposure scenario would not be included within an extended SDS:
- The substance is classified as not dangerous (non-hazardous)
- The substance is exempted from REACH.
- The substance is manufactured/ imported in volumes less than 10 t/year.
- The substance will be registered at later REACH deadline (2013 or 2018).
- The substance in a mixture will be registered at later REACH deadline.
If you need any assistance on REACH please do not hesitate to contact your local contact at IMCD or our HSEQ Coordinator Mr. Michael Paetzold (REACH@IMCDGROUP.COM).
If you want to request a Safety data sheet please send us an email using the following address: SDS@IMCDGROUP.COM.
