Dear Customer,
The REACH, (Registration Evaluation Authorization and restriction of Chemicals) regulation has came into force on the first of June 2008. We are preparing ourself for this very important new chemical legislation which is complex and has a long and staged approach to implementation. REACH is base on pre-cautionary principle and reverse burden of enterprise to improve the current chemical regulations.
This letter seeks to clarify the situation with regard to how Aromate will be to regard by the REACH and how we will be preparing for the new rules.
The REACH rules which are related us:
- Not all the ingredients in a fragrance have to be registered: only those which are produced or imported into the EU at greater than 1Ton a year.
- Registration of these ingredients will take place over an 11 year period based upon the quantity produced or imported a year.
- Under REACH all of us involved in the supply chain for chemical substances will have obligations, whether you are a manufacturer, importer, down stream user.
Aromate intends to meet its obligations under REACH, however Aromate does not produce ingredients and so we are now reviewing raw material usage data with suppliers and ensuring they are complying with REACH regulation. Over the period to June 2008 we will ensure that all materials used in the quantities greater than 1 Ton a year for European market are:
- Manufactured in EU are registered by suppliers for use in fragrances.
- Ingredients manufactured outside of EU, we will ensure the suppler/ agent is capable to register them for use in fragrances.
However, we cannot fully guarantee that substance may not be lost due to uneconomic costs, lack of support from suppliers or by unexpected issues. We will do our best to work with our suppliers to minimize potential impacts. Once the REACH has clearer picture on the new MSDS format and restrict ingredients information, we shall apply it on to our MSDS. In the meantime the regulation details are not finalized, the MSDS we provide will stay the same. Nevertheless, we are here to address that Aromate will follow the REACH regulation and treat it as an obligation for the respect of our environment.
Jane Huang
Director of Product Development Dept.
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