REACH – (EC) 1907/2006
The acronym REACH stands for Registration, Evaluation, and Authorization of Chemicals. REACH takes precedence over most pre-existing EU Chemical Regulations. The requirements of 76/769/EEC and 67/548/EEC are carried over into REACH. REACH applies to all substances that are used in quantities of greater than 1 tonne per year per importer or producer with an implementation time line that stretches from 2007 to 2018. The responsible party for REACH is the manufacturer (if based in the EU) or the importer. The threshold quantities apply per manufacturer or importer, not per product line.
There are two main scenarios where Quilter , LLC may be affected by REACH. These are:
Quilter has conducted an assessment of the regulations and has determined that our current product offerings do not fall into category 1. Accordingly, we foresee no registration or authorization requirement for the products we produce. With regard to category 2, the requirements of Article 33 of REACH: Duty to communicate information on substances in articles; we declare no knowledge of any of the SVHCs are present in Quilter’s products except for lead monoxide and DEHP in quantities totaling in a concentration equal or above 0.1%. As new products are designed and released, and the SVHC list is updated, Quilter will continue to monitor the components and subassemblies to ensure compliance.
- The product contains a chemical substance intended to be released during normal and reasonably foreseeable conditions of use, such as ink in a pen, and more than one tonne per annum is put onto the EU market.
- The product contains a chemical substance listed as a “Substance of Very High Concern” in a concentration of >0.1% wt/wt. These substances are linked to human health issues or are environmentally “persistent, bio accumulative and toxic”
Statement of CARB Compliance
The CARB rules were phased in during 2011, Quilter wants to make you aware of what we have done to meet this Rule. We have accomplished the following:
- Confirmed that our partners are aware of the formaldehyde emissions rules; Per the California Air Resources Board’s measure, Quilter and Quilter’s contract manufacturers are considered “Fabricators”. A company that manufactures domestic or imported finished goods made with regulated composite wood panels. Quilter and Quilter’s partners have been compliant with the CARB Rule since January 1, 2010 and have been buying compliant material from our suppliers since May 1, 2009.
- Determined what steps have already been taken to produce compliant products; What are the Fabricator requirements? What has Quilter done to meet these requirements?
- Enter into agreements with wood suppliers to supply only CARB compliant material starting May 1, 2009; and receive written certification from the suppliers on all material shipments.
- As the compliant material is received, keep the records of purchases for two years (the bill of lading or the invoice received from the supplier clearly identifying the supplier and certifying that the panels are CARB compliant with the third party certification agency identified).
- Fabricators Name
- Date Finished Product was Produced (this is imbedded in the Product Serial Number)
- Language that clearly indicates that the product complies with the CARB Rule.
- The same statement of compliance in c) is also on the invoice and Packing slip that is sent to our customer.
- Notify all customers that going forward Quilter will provide compliance certification and will only be purchasing compliant materials.
Quilter has been supplying fabricated products containing composites that comply with the labeling, emission and certification requirements of the rule since January 1, 2010.
Quilter certifies that all Quilter products containing MDF or Hardwood Plywood comply with CARB Phase 2 formaldehyde emission standards in CCR 93120.2(a).
Click Here for a certificate of compliance