Belmay Reach Policy
Belmay is actively working on a REACH program which, we believe, will make it unnecessary for our customers to register the substances in our products under REACH.
We are working at the highest levels within industry groups and associations, and within various governmental offices to ensure the best possible outcome for all. Please see below a list of the steps we are taking:
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In compliance with Article 8, Belmay, LTD will be our Only Representative (OR) for all non-EU Belmay, Inc. manufacturing facilities,
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Belmay, LTD will pre-register all the ingredients we use in any quantity throughout the world.
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By ensuring all substances we use are pre-registered there will be guaranteed continuity of supply for our fragrances after the December 1st 2008 pre-registration deadline
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We will work with our customers on supplying information which they require for REACH, however availability of information will be determined by the pre-registration process
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The pre-registration process is ongoing and will be completed before the end of November
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Once we have pre-registration numbers for substances these will be supplied on an as needed basis to our customers for their use
As an aide to our customers, below is Belmay’s understanding of the requirements for REACH
Scope of REACH. REACH is concerned with registration of substances and not with registration of preparations such as fragrance compounds; therefore, no fragrances as such need to be registered.
Pre-registration of substances. To allow the continued use or import of a substance to the EU, after December 1st 2008, it is a requirement to pre-register the substance. Only phase-in substances can be pre-registered and these are essentially items on the EINECS list.
Substance quantities of 1 metric ton per annum. If products sold by a customer into the EU contain, on aggregate, any single substance in quantities of 1 metric ton or greater (on an annualised basis), registration of any such substance will be required.
Substance quantities of 100 metric tons per annum If products sold by a customer into the EU contain, on aggregate, any single substance in quantities of 100 metric tons or greater (on an annualised basis), registration of any such substance will be required.
Substance quantities of 1,000 metric tons per annum If products sold by a customer into the EU contain, on aggregate, any single substance in quantities of 1,000 metric tons or greater (on an annualised basis), registration of any such substance will be required.
Registration timelines. For registration of substances at the 1,000 metric ton level, the REACH timeline shows that registrations are required to be complete by December 1st 2010.
For registration of substances at the 100 metric ton level, the REACH timeline shows that registrations are required to be complete by June 1st 2013.
For registration of substances at the 1 metric ton level, the REACH timeline shows that registrations are required to be complete by June 1st 2018.
Exceptions. There are exceptions to the above for certain classes of substances of special concern:
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For CMR (Carcinogenic, mutagenic or toxic to reproduction) substances, at usage levels of 1 metric ton or greater (on an annualized basis), registration must be completed by December 1st 2010
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For R50-53 substances, at usage levels of 100 metric tons or greater (on an annualized basis), registration must be completed by December 1st 2010
If you have imported any individual ingredient into the European Economic Area (EEA), which includes all EU member states and Norway, Iceland, and Liechtenstein, and plan to continue to import into this region, all materials in Belmay, Inc. formulations will be pre-registered and you should experience no disruption in service.
We are available to answer any questions or concerns you may have and encourage you to contact us at reachteam@bel.com.
Sincerely,
Global REACH TEAM
Belmay, Inc.
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