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Dear Sir or Madam,
thank you for your request regarding our information requírements for,,Substances of
Very High Concern" (,,SVHC"; Candidate List of Substances of Very High Concern for
authorisation) in our articles according to Article 33 of the REACH-Regulation (EC) No
190712006 (REACH). As ,,downstream user" and as ,,supplier of an article" under
REACH we are forced to pass on information along the supply chain. Unfortunately it
is unclear to many companies what these information requirements actually mean.
This often results in situations where companies along the supply chain urge each
other to confirm ,,REACH compliance" of articles. Such statements are not intended by
REACH. For companies they only cause additional expenses, but generate neither
legal certainty nor other real benefit. Therefore we would like to inform you what
information you will receive from us as ,,supplier of an article" in accordance with the
requirements of REACH.
lnformation requirements according to Article 33
According to Article 33(1) REACH, any supplier of an article containing a substance
meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a
concentration above 0,1 o/o weight by weight (w/w) shall provide the recipient of the
article with sufficient information, available to the supplier, to allow safe use of the
article including, as a minimum, the name of that substance.
lf such cases occur we will properly comply with the information requirements in order
to ensure the safe handling of our high quality articles. We are in close contact with
our suppliers and have never received any information on SVHC in articles. On the
basis of our risk assessment there are no indications which will lead to a specific
sample analysis up to now. According to the information available we currently assume
thatourarticles do notcontain anySVHC in a concentration above 0,1 o/o weight by
weight (w/w). Once we have further information we will inform you immediately and
coordinate appropriate measures. Due to our broad range of articles and due to the
fact that we are depending on the information coming from our suppliers, who also
have to fulfilthe information requirements, you wíll certainly understand that we are not
able to give further legally binding statements.
REACH implementation in our company
The expert group ,,Environment and occupational safety" of WSM Wirtschaftsverband
Stahl- und Metallverarbeitung e.V. - we are involved in the expert group via our
industry association VDMA - regularly informs us about proposed substances for the
Candidate List, public consultations, updates of SVHC on the Candidate List and about
the relevance of SVHC, whereby we fulfil the required timeliness of the survey. The
published information on uses of SVHC show that the products supplied do not contain
any of these substances.
By sending you this information letter to fulfil our information requirements as a
,,supplier of an article" according to Article 33(1) REACH we are following legal
provisions, recommendations of WSM Wirtschaftsverband Stahl- und
Metallverarbeitung e.V. and our industry association VDMA.
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