STATEMENT OF AVON METALS LTD REACH STATUS

Transcription

1 STATEMENT OF AVON METALS LTD REACH STATUS Avon Metals Ltd UUID IUC5-f14b57de-b7a0-4fb4-b4f2-0f5267ea504e Avon Metals Ltd reviews its REACH compliance status, by periodic assessment of their incoming materials to ensure their continued compliance to the REACH regulations. We will fully register any substance that becomes liable for such registration. As a matter of preparedness, all the substances that we currently sell on their own or in alloys (considered special preparations) have been pre-registered together with a number of substances we may trade in the future. In this way, we can proceed to full registration as and when the need arises. The following statements describe Avon Metals Ltd current status on REACH: Avon Metals Ltd is not the prime manufacturer of any of the substances we trade or use in our alloys and as such have no legal obligation to pre-register or fully register these substances. Similarly, in many cases Avon Metals Ltd are not the primary importer of the substances we trade or use in our alloys, as they are all sourced from EU suppliers and Avon Metals Ltd is therefore considered a downstream user and again has no legal obligation to pre-register or fully register these substances. In those cases where substances are imported into the EU, Avon Metals Ltd has registered or preregistered those substances to allow REACH compliant importing. Pre-registered substances will be fully registered when the annual tonnage importation exceeds that allowed by the preregistration. Avon Metals Ltd also procures much of its feedstock from secondary/scrap sources from which it recovers substances. Such substances are exempted from Title II (Registration), Title V (Downstream Users) and Title VI (Evaluation) as described in the Reach regulations, (EC) No 1907/2006 Article 2 (7) d, which states the following: 7. The following shall be exempted from Titles II, V and VI: (d) substances, on their own, in preparations or in articles, which have been registered in accordance with Title II and which are recovered in the Community if: (i) the substance that results from the recovery process is the same as the substance that has been registered in accordance with Title II; and (ii) the information required by Articles 31 or 32 relating to the substance that has been registered in accordance with Title II is available to the establishment undertaking the recovery. To enable the potential sourcing of cheaper materials from outside the EU, Avon Metals Ltd regularly reviews it substance requirements to determine if full registration is prudent to allow the import of these substances into the EU, should the quantity, quality and commercial case be made to do so.

2 General Statement related to Dangerous Substances The metals and alloys that Avon Metals Ltd sells:- 1. do not contain any substance listed in Annex XIV to EC Regulation 1907/2006 (Substances requiring an Authorization) 2. do not contain any substance listed in Annex XV to EC Regulation 1907/2006 (Substances of Very High Concern). Furthermore, our products do not contain any substance included in the current Candidate List 3. do not contain any substance classified as CMR (Carcinogenic, Mutagenic, or toxic to Reproduction) according to the criteria for classification in category 1 or 2 in accordance with EC Directive 67/548 and EC Regulation 1272/ do not contain any substance classified as PBT (Persistent, Bioaccumulative, or Toxic) according to EC Regulation 465/ do not contain any substance classified as vpvb (very Persistent or very Bioaccumulative) according to EC Regulation 465/ do not contain any substance with risk level equivalent to the above categories to the best of our knowledge. A list of the substances with their pre-registration numbers and where applicable their full registration numbers is given in Appendix 1 of this document.

3 Appendix 1 - List of Substances Substance EC CAS Reach Pre-Registration Expiry of Pre- Registration Reach Full Registration Aluminium Nov Ammonium Perrhenate May xxxx Antimony May xxxx Beryllium May xxxx Bismuth May xxxx Boron May xxxx Calcium May xxxx Carbon May xxxx Cerium May xxxx Chromium May xxxx Cobalt May xxxx Copper May xxxx Dysprosium May 2018 Not Available Erbium May 2018 Not Available Gadolinium May 2018 Not Available Gallium May 2018 Not Available Hafnium May xxxx Hafnium Dioxide May xxxx Indium May 2018 Not Available Iron May xxxx Lanthanum May xxxx Lead May xxxx Magnesium May xxxx Manganese May xxxx Molybdenum May xxxx Neodymium May xxxx Nickel May xxxx Niobium May xxxx Potassium tetrafluoroaluminate May xxxx Praseodymium May 2018 Not Available Rhenium May xxxx Ruthenium May 2018 Not Available Scandium May 2018 Not Available Scandium Oxide May 2018 Not Available Selenium May xxxx Silicon May

4 Substance EC CAS Reach Pre-Registration Expiry of Pre- Registration Reach Full Registration Silver May xxxx Strontium May 2018 Not Available Tantalum May xxxx Tellurium May xxxx Tin May xxxx Titanium May xxxx Tungsten May xxxx Tungsten Carbide May xxxx Vanadium May xxxx Yttrium May 2018 Not Available Zinc May xxxx Zirconium May xxxx Zirconium Dioxide May xxxx Avon Metals Ltd own full registration numbers are given in bold type. Other full registration numbers listed with the last four digit id section blanked, are to show that those substances have been registered in the EU to satisfy the requirements of (EC) No 1907/2006 Article 2 (7) d and our responsibilities as downstream users from EU sourced substances.

5 Document Update Log Date/Ref 03-Jun Jun Jul Feb Dec Apr-2015 Details Original 1. Company Letterhead updated - Update of Queens Award status: Removal of expired 2007 award logo, addition of latest 2012 award logo. 2. Company Letterhead updated - Logos for QMS and EMS accreditation updated to take account of ABS replacing BSI as the accreditation body. 3. Column added to the List of Substances to report the expiry date of the preregistration number. 1. REACH registration number added for Silicon 2. Corrected Date/Ref error on Document update log a. 03-May-2013 corrected to 03-Jun-2013 b. 05-May-2013 corrected to 05-Jun Paragraph added about the full registration of Aluminium and Silicon 1. Section added stating that the metals and alloys sold by Avon Metals Ltd do not containing dangerous substances as defined in the EC Regulations or Directives 1. Added AML UUID IUC5-f14b57de-b7a0-4fb4-b4f2-0f5267ea504e 2. Addition of non AML Full Registration numbers to show that those substances have been registered in the EU to satisfy the requirements of (EC) No 1907/2006 Article 2 (7) d and our responsibilities as downstream users from EU sourced substances. 1. Addition of a statement on Pre-Registration 2. List reordered Alphabetically 1. Statement on Pre-Registration amended slightly 2. Removed statement that Aluminium and Silicon are full registered as this is advised in the table of substances. 3. Logo Changed Queens Awards Logos Removed as they have now expired