Statement of REACH Compliance
The EU legislation No. 1907/2006 or REACH regulations (Registration, Evaluation, Authorisation and restriction of CHemicals) came into effect on the 1st June 2007. The main objectives of the regulations are to ensure that chemical substances used within the EU are properly assessed for their safety to both humans and the environment and where appropriate the use of some substances may be restricted or prohibited. Registration is required for all substances and preparations which are manufactured or imported in volumes of 1 tonne or more per annum, in the EU member states under this new legislation.
In light of this requirement, ROMIL would like to make clear its position, as the chemicals and solutions manufactured and marketed by us are produced from materials sourced within the EU. This places ROMIL in the REACH supply chain as a “Downstream User” rather than as a “Manufacturer or Importer” of products.
The manufacturers or importers need to include downstream uses in their registration dossiers. This means that information will have to pass up and down the chemical supply chain to ensure all relevant uses are registered for the different substances. We would like to emphasise that as a downstream user, ROMIL is fully aware of its legal obligations and responsibilities towards both customers and suppliers and is currently taking the necessary actions.
However, being a pre-eminent producer of high purity Acetonitrile we do on occasion import this raw material from outside the EU and thus makes it the only product where ROMIL is classified as an “Importer”. Again, we are aware of the legal obligations and responsibilities and as such have completed the required dossier for pre-registration.
At ROMIL we believe that for a successful integration of the REACH regulations communication within our supply chain is vital. At the moment we are maintaining a close contact with all of our suppliers with regard to their own pre-registrations. They are confirming that chemical materials supplied to ROMIL will indeed be pre-registered with the intent of full registration at the appropriate time.
As our supplier chemical information review draws to an end over the forthcoming months our attention will turn towards our customers to assist with their individual REACH implementation requirements. In many cases we already know what applications our products are used for. However, it may be necessary, in certain cases, for us to request further information from customers. If this information is confidential we will of course respect this, as the legislation does provide for this.
To conclude, we are confident that the ROMIL product range will continue to remain available after the 1st December 2008 pre-registration deadline as fully REACH compliant.