AlphaGary

Globally positioned, locally responsive

REACH

AlphaGary REACH Position Statement

R egistration, E valuation, A uthorization and the restriction of CH emical substances was enacted with the stated goal of improving the protection of human health and the environment from the risks of chemicals while enhancing the competitiveness of the EU chemicals industry. Earlier legislation was not adequate for assessing the impact of chemicals, especially for “existing chemicals” for which little health and environmental data was available. REACH was adopted in December, 2006 by the European Parliament and later that same month by the Environment Council. It entered into force on June 1, 2007.

One important distinction from earlier chemical regulations is that REACH transferred the burden of assessing chemical safety from government agencies onto the manufacturer or importer of those substances.

REACH affects any legal entity that imports one metric ton or more per year of a chemical substance into the EU. Substances must be registered with the new European Chemicals Agency (ECHA) in Helsinki under a defined timetable. Failure to properly register a substance means that it can no longer be manufactured, imported or marketed in the EU. However, companies can take advantage of a “pre-registration” period that allows them to manufacture, import and market so-called “phase-in” substances (i.e. existing substances) until the required registration deadline. The pre-registration period runs from June 1, 2008 until December 1, 2008, inclusive.

REACH addresses the human health aspects of chemicals, in part, through the disclosure of operating scenarios to cover the uses and applications of those substances. We have notified our suppliers that they must include an exposure scenario for “compounded thermoplastic materials.” It you believe that your application or use of AlphaGary products will not be adequately addressed by this operating scenario, please notify us so that we can communicate this through the supply chain.

We understand the importance to our supply chain of complying with REACH. Failure to meet the necessary requirements can cause significant disruptions to the whole supply chain. Therefore, we are striving to meet our REACH obligations and prevent such disruptions. If you have any questions, or need assistance in your responses to the REACH requirements, please don’t hesitate to contact us.

REACH Contacts;

Europe - Adam Killoran - akilloran@alphagary.com

USA - Troy Brantley - tbrantley@alphagary.com