November 2008

REACH

REACH; the European Union regulation for the Registration, Evaluation, Authorisation and restriction of Chemicals entered into force in June 2007. REACH is an on-going compliance process which will have a significant impact to the business of all manufacturers, importers and downstream chemical users. All have specific obligations under the new legislation and Champion Technologies is well informed of such developments.

Pre-registration of Existing Substances

The REACH regulation allows for the pre-registration of existing substances to enable importers and manufacturers to benefit from transitional periods for full registration of substances. This is to ensure that there will be no disruption in the supply and marketing of these substances to Downstream Users (DU) during the registration period. The pre-registration period lasts for 6 months and expires on the 30th November 2008.

We recognise that information on REACH status of our products is critical to our customer’s assessment of REACH impact and we are willing to share the REACH registration status of products with customers. Ensuring full continuity of business relationships throughout implementation of REACH is of primary concern to Champion Technologies. We are able to provide necessary information to help you fulfil your obligations as a downstream user or chemical supplier.

Pre-registration numbers

The European Chemicals Agency (ECHA) will assign individual pre-registration numbers - this is not required in the REACH Regulation. These numbers are intended for administration purposes only between ECHA and the pre-registrant. There is no legal provision which can be fulfilled by a DU using the pre-registration numbers of their suppliers. Therefore the pre-registration number should not be regarded as a means to communicate in the supply chain. Requesting pre-registration numbers from suppliers will not safeguard supply for the following reasons:

• Not all substances need a pre-registration number;
• Substances exempt from REACH do not get pre-registration numbers;
• Substances manufactured or imported within the EU in quantities of less than 1 tonne do not have to be pre-registered.
• The pre-registration number can be created or copied easily by any person having access to the REACH-IT system;
• The number cannot be automatically linked back to a substance or a legal entity;
• The ECHA will not publish lists of pre-registered numbers linked to legal entities so there is no way to check if a pre-registration by a specific legal entity has occurred;

Champion Technologies cannot supply pre-registration numbers where we do not have them, but we have obtained the necessary assurances from our EU suppliers so we can maintain security of our existing supply chain during and after the REACH preregistration period.

Where we have future indications from suppliers that they will be unable to maintain supply we will either; source alternative EU suppliers, identify alternative products, or pre-register as a first time importer. This will guarantee supply of the specific Champion Technologies products required.

If you wish to contact Champion Technologies for further information our REACH implementation team can be contacted at REACH.EU@champ-tech.com