What do you mean by REACH compliant? I am assuming that SVHC is present or the product is an SVHC.
To my understanding, an entity that incorporates articles to create a product is responsible to track any REACH identified SVHCs that are present in the product. When sales of the product provide an exceeding of the substance(s) aggregate limit(s) for reporting, then reporting is to be made. Christine would request from the OEM a statement indicating if any of the identified SVHCs are present in the product that is being incorporated into product. If the OEM product is an identified substance then reporting is required. Regards, Denis Ryskamp Environmental Compliance Manager Trimble Dayton 5475 Kellenburger Road Dayton, Ohio 45424 *: 01-937-245-5539 *: denis_rysk...@trimble.com ________________________________ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of lauren_cr...@amat.com Sent: Wednesday, April 08, 2009 3:18 PM To: chrisrod...@yahoo.com Cc: emc-p...@ieee.org Subject: Re: REACH Enforcement No clear ideas on how and if real enforcement will occur, but except for a very few issues in REACH, response to obligations don't "port" across import streams. That is to say, it doesn't matter what anyone else is doing for a specific product, whether they be the OEM or a distributor, or a gray-market re-seller, an EU importer is directly and totally responsible for the REACH conformance of the products they import. An importer could have contractual arrangements with their suppliers and push conformance obligations to the supplier, but the importer is still on the hook. One (external to the EU) can sell non-conforming products to unsuspecting importers (in the EU) all day long without being in danger of REACH violations. It might violate the fine print terms and conditions in the contracts one has established with their in-EU clients. A more detailed response depends on who is internal and external to the EU in the supply chain you describe, and who is a client of who (whom?) Regards, Lauren Crane Product Regulatory Analyst Corporate Product EHS Lead Applied Materials Inc. Austin, TX 512 272-6540 [#922 26540] - external use - Save paper and trees! Please consider the environment before printing this e-mail. Christine Rodham <chrisrod...@yahoo.com> Sent by: emc-p...@ieee.org 04/08/2009 02:01 PM Please respond to chrisrod...@yahoo.com To emc-p...@ieee.org cc Subject Re: REACH Enforcement List Members, We have an OEM that has a product we want to sell in Europe that is not REACH compliant. Since the OEM introduced the product into Europe via their reseller are there any ramifications to us for selling this product without it being compliant to the REACH Directive? The product is a network Intrusion Protection /Monitoring Device which could be used with a Server. Any input on REACH enforcement in general is appreciated! Thank you in advance! Christine Rodham - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. 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Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@ptcnh.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com>
