EU chemicals regulation REACH

The current status at LEONHARD KURZ Stiftung & Co. KG (November 7, 2024)

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.

KURZ, as a downstream user, only utilizes raw materials and substances for its transfer products that, according to information provided by our suppliers, are not subject to authorization requirements under Annex XIV dated April 8, 2022. At KURZ, we do not incorporate SVHC substances from the candidate list in the production of our transfer products.

Should any changes in the classifications of raw materials used herein or amendments to the SVHC list affect transfer products (REACH / Art 33; > 0.1% by weight of authorized ingredients), we will duly inform our customers in a separate communication, including the SCIP number, as required by law. In such cases, an immediate substitution program will be initiated in consultation with our customers.

For our customers, this means that, when using our transfer products for the intended purpose of enhancing their products, normally no further REACH-related activities regarding our transfer products 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.