The current status at LEONHARD KURZ Stiftung & Co. KG (June 2023)
According to the EU regulation 1907/2006 dated 18th December 2006 (REACH REGULATION), our finishing products are classified as articles and therefore are not subject to registration. Therefore, the preparation of a safety data sheet is not mandatory for our finishing products. For the customer using the finishing products this means that the duty to check whether special requests or restrictions resulting from the used raw materials have to be considered is not applicable. Additionally the finishing product (article) fulfills the requirements of article 67 (REACH REGULATION) and complies with the conditions of the restrictions listed in Annex XVII.
We as a downstream user use only such raw materials and substances for the manufacturing of our finishing products, which according to the information of our suppliers are not subject to authorization requirement as of Annex XIV (updated on 2021-11-24) of the REACH regulation. Also no substances on the Candidate list (Substances of Very High Concern) as updated on June 14, 2023 are included in our finishing products in a concentration above 0.1 % weight by weight.
If either by modification or reclassification of raw materials the duty to pass information about substances in articles (REACH / article 33; >0,1% weight by weight substances to which authorization will apply) will be required, we will inform you immediately.
If customers use our finishing products in the proper manner to embellish products, those finishing products are in conformity with REACH and no further activities regarding REACH regulation are necessary.
What is REACH?
General information about REACH
REACH: Registration, Evaluation and Authorization of Chemicals
The official purpose of REACH is to protect human health and the environment while guaranteeing the free movement of substances within the internal market, improving the competitiveness of the chemical industry, and fostering innovation. Adherence to this ordinance will be monitored by the European Chemicals Agency (ECHA) in Helsinki.
REACH is founded on the principle that manufacturers, importers and downsteam users need to guarantee that they are manufacturing, putting on the market and using substances that will not negatively impact on human health or the environment. Its provisions are based on the duty of care principle.
If a manufacturer does not comply with his registration or approval obligations, he will no longer be allowed to market these substances or preparations. The end-user must not use them either.
Who is affected
Manufacturers – importers – downstream users
Who has to register or obtain approval for his substances?
All manufacturers or importers within the EU who:
- manufacture or import substances in quantities > 1 t/a (registration),
- release substances under normal conditions of use (registration),
- where the substance is listed in Annex 14 of the REACH ordinance and is present in end products at a concentration > 0.1 percent by weight (approval).
Downstream users are subject to a disclosure and monitoring obligation:
- They need to check the safety data sheet (SDS) and implement any risk management measures specified therein.
- They need to inform their suppliers of the specific mode of use of the material being purchased.
- If they are creating their own preparations, they need to produce their own SDS and supply it to their customers.