Dear  Valued Customer,

 

         The European Regulation 18th December 2006 concerning Registration, Evaluation, Authorization and Restriction on Chemicals (REACH) entered in in to force on 1st June 2007 and will be phased in until 2018.

          REACH establishes specific duties and obligations on a business in the European Union (EU) which manufactures or imports a substance or article that includes a “substance of very high concern” (SVHC) in concentrations of more than 0.1% w/w. with the aim of identifying their hazardous properties and recommending appropriate risk management measures along the supply chain.   

  

         TMK ARTROM is fully aware by this new European Regulation which replace numerous EU law related to chemicals and complementary to other environmental and safety legislation using his  best effort to comply with it.

          From the beginning, it was made an inventory of the substances covered by REACH and ensured that all substances that are in the goods (seamless tubes) supply to you have been preregistered and registered either by our suppliers.

          TMK ARTROM made also a risk management evaluation regarding SVHC9 (Substance of very high concern).

         As of January 15, 2018, there were 181 substances on the SVHC list and 43 substances on the Authorization List. Further, the use of substances listed in Annex XVII of the REACH Regulations are banned in all articles or substances produced or imported in the EC except to the extent that the use complies with the specific restrictions contained in Annex XVII.

On 27 June 2018 Echa has added eight new SVHC’s to the Candidate List following the SVHC identification process with the involvement of the Member State Committee (MSC).Substances included in the Candidate List for authorization and their SVHC properties can be found at: https://echa.europa.eu/-/ten-new-substances-added-to-the-candidate-list

        There are not Substance of Very High Concern from the Candidate List above in the seamless steels  tubes we produce or in the steel produced by our billets supplier. We are constantly monitoring the Candidate list of SVHC’s and we will inform you in case of inclusion of a substance contained in our steel products, as foreseen in the Reach Regulation.

 

We like to draw your attention that the goods supplied to your company are considered as articles in the sense of REACH Article 3(3) and therefore are exempt from requirements of registration .Our products are not subject to classification under CLP regulation (REGULATION EC No 1272/2008 )  .

 

For more information and details we recommend to  see “ECHA ‘s Guidance on article ” and “ Eurofer position paper” available at the following locations:

https://echa.europa.eu/documents/10162/23036412/articles_en.pdf

http://www.eurofer.be/Issues%26Positions/REACH/REACH.itpl

   

        We do not anticipate any significant change induced by REACH, but in case of changes we would keep you informed of it as soon as possible.

        We are at your disposal for questions about the safe use of our products. For  any additional information you may require please feel free to contact us by e-mail  to office.slatina@tmk-artrom.eu (for the attention of Mrs. Magdalena Popescu) or to make o phone call to   + 40723209646 .

    

Yours faithfully,

 

Quality, Environmental &Integration Management System

 

Magdalena Popescu