Dear Valued Customer,
S.C. TMK-RESITA is fully aware of the requirements of REACH, the new European Union (EU) Regulation on the Registration, Evaluation and Authorisation of Chemicals. The REACH Regulation is aimed at the safe use of chemicals. It replaces numerous EU laws related to chemicals and is complementary to other environmental and safety legislation. This legislation was approved by European Parliament and its Council and came into force on June 1, 2007.
S.C. TMK-RESITA has always been responsible for their products following the internal or international legislation in force regarding quality, environment or health and safety and security.
As a result, we have been looking for the effect of the REACH Regulation in our company, on our customers and vendor base.
According to the European Confederation of Iron and Steel Industries (EUROFER) position, slabs, blooms, billets, machined, dressed ingots and final steel products are articles, and are therefore all exempt from the requirement of registration.
This position, which is supported by the global steel industry (in so far as it applies to EU law), was determined from the European Chemicals Agency's (ECHA) "Guidance on requirements for substances in articles", where it can be clearly argued that semi-finished steel products have a special shape, surface, or design which determine their function to a greater degree than their chemical composition does. The EUROFER position was recently acknowledged by ECHA in writing.
The EUROFER position assumes that semi-finished steel products are re-shaped into finished steel products. Nowhere in the manufacturing chain is the semi-finished product re-melted (i.e. back to a preparation). Were this to happen, the article-article chain would be broken and registration obligations may apply.
In addition, we made an inventory of the substances covered by REACH gathering related data in order to be sure that the consequences of REACH for our upstream supply chain remain under control. For all material used in the processing flow TMK-RESITA is considered as a downstream user under REACH. We compiled a list of all the ingredients used and all suppliers; from TMK-RESITA decided to contact their; suppliers. After making enquiries, we found that the chemicals were pre-registered, will be registered in due time, including our uses. The suppliers indicated that they would get back in touch with us once they start compiling the registration file.
Should you have any question regarding the above mentioned information, feel free to contact us; the REACH responsible on mobile phone +40 723 209 646 or via e-mail firstname.lastname@example.org (for the attention of Mrs. Magdalena Popescu).