What is REACH?
REACH is the Regulation for Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force on 1st June 2007 to streamline and improve the former legislative framework on chemicals of the European Union (EU). REACH places greater responsibility on industry to manage the risks that chemicals may pose to health and the environment.
In principle REACH applies to all chemicals: not only chemicals used in industrail processes but also in our day-to-day life, for example in cleaning products, paints as well as in articles such as clothes, furniture and electrical appliances.
How does REACH apply to fasteners?
REACH defines an article as "an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition does." Articles are exempt from REACH unless they contain substances of very high concern (SVHCs). If they do contain any SVHCs, they may still be exempt, subject to additional criteria involving concentration, annual weight imported to the EU and likelihood of the substance being released during normal use. If the substance is not intended to be released, but it is a substance of very high concern, the manufacturer may have an obligation to notify the Agency.
PennEngineering® fasteners meet the definition of articles under REACH. They do not contain substances of very high concern and therefore we do not have an obligation to notify the Agency.
How does REACH impact PennEngineering?
PennEngineering manufactures fasteners both inside and outside of the EU and is compliant with REACH legislation under each of these scenarios, specifically:
PennEngineering's manufacturing entity in Europe (PEM Europe) is classified as a DU (Downstream User) under REACH legislation. Our obligations under REACH are to ensure that our upstream supplier of chemicals has registered these chemicals and that all Material Safety Data sheets for their site are available upon request.
PennEngineering manufacturing outside of the EU is also compliant. The fasteners it supplies are classified as articles imported into the EU and as such are exempt.
Which PennEngineering Fasteners are REACH compliant?
All PennEngineering fasteners are currently compliant as they do not contain or release any substances that are on the current SVHC (Substances of Very High Concern) list.
How might future changes to REACH impact PennEngineering?
Future changes planned for REACH at this time will restrict the use and importation of SVHCs into the EU. Since our EU facility does not use any substances currently on the SVHC list, it will have no impact on PennEngineering unless a substance used in our EU facility is added to the SVHC list.
How might future changes to REACH impact PennEngineering fasteners?
If an ingredient used in fastener products is added to the SVHC list, the product may loose its article exemption. Although we have no current indication this will happen, there is no assurance that it can never happen. Before a substance is added to the SVHC list it will first be presented as a candidate for addition. This allows arguments for and against their addition before it happens.
The SVHC candidate list is composed of substances which are either Carcinogenic, Mutagens or harmful to reproduction. These additions are being monitored regularly and any addition possibly having an impact on PennEngineering will be flagged well in advance.
Who can I contact for more information on REACH and PennEngineering fasteners?
A REACH team has been formed and can be contacted at REACH@pemnet.com
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