Registration Evaluation & Authorisation of Chemicals
In addition to the substances listed in a new European Community Regulation on chemicals and their safe use came into force on 1st of June 2007 called REACH (Registration, Evaluation and Authorisation of Chemicals). REACH is about identifying the chemicals/substances used in an article that is imported into the EU and registering them with the European Chemicals Agency (ECHA) if we import over a certain amount of this chemical/substance per year. Everybody should flow Safe Chemical Handling Procedure
An article is defined in REACH as an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. In a general sense an article can usually be considered to be a finished product, which is manufactured from raw materials that are substances.
REACH is to ensure the control of any harmful chemicals/substances exposed to humans or the environment and the safe use of an article. Also to identify chemicals/substances which are not intended to be released from the article (compared to chemicals/substances that are intended for release from an article). In particular, we include CMR substances, which are substances belonging to category 1 or 2, which are of a carcinogenic category, mutagenic or toxic for reproduction, PBT substances (persistent, bioaccumulative and toxic) and vPvB substances (very persistent and very bioaccumulative). You can find further information in the guideline 67/548/ECC among other sources.
We assume that all products you are supplying us will satisfy the requirements of the enclosed "Restricted Substances List" (01-20041-en) and request that you again confirm this in writing with the enclosed Annex 1. In the event that you have checked "yes" at least once in annex 1, please also return Annex 2 to us. The duty to provide information pursuant to the REACh regulation concerns in particular substances of very high concern with a concentration over 0.1 % in the product. A limited number of CMR substances exist, whose limit value may exceed this threshold according to statutory requirements such as specific Phthalates (DEHP, DBP, BBP) in non-textile products or Cadmium in batteries. In order to provide consumers with secure information corresponding to the requirements of the regulation, we are counting on your cooperation in this matter and therefore kindly request that you complete the attached documents.
At present, we have not yet decided how we will deal with products containing substances of very high concern - which are permitted by law - in future. In particular, this depends on the information you provide. Providing we obtain a detailed profile on the basis of your responses, we will decide whether we will also continue to purchase such products in future. Notifying our customers that a product contains more than 0.1 % CMR substances may seriously detriment the image of Noel Soccer as well as that of your company. As such, we ask that you assist accordingly in providing information and at the same time evaluate whether these CMR substances can be replaced with non-hazardous substances.
For any articles containing any SVHC (Substances of Very High Concern) from the candidate list in concentrations above 0.1% (w/w), EU manufacturers and importers are obliged to provide safe use information or a Bill of Substance to their recipients and consumers within 45 days upon request.
In order for us to be in compliance with this obligation, we require to keep details of the substances used within each article, including the chemical contents of each component of the article.
For example in regards to accessory suppliers, we need to keep a list of the chemicals you use in the production of fabrics, linings and interlinings, the bleaching, dyeing and finishing of the fabric, the thread used to sew the garment and the contents of any trims used on the garment e.g. labels, buttons etc. Packaging of any description is also considered an article under REACH.
We & our customers carry out ongoing risk assessments of each of our items purchased/used in our garments to identify which Substances of Very High Concern (SVHC) might be in them. In order to do this accurately we need your help in providing us with so called chemical data sheets/bill of materials of the articles you supply to us.
Suppliers must take action today to ensure they are REACH compliant and able to communicate the required information regarding Banned Substances in their products. Suppliers need to fully understand the content of the chemicals being used in any of their processing, identify substances that are not permitted and provide alternatives. The total number of SVHCs on the candidate list to date is 151. It is each supplier’s responsibility & legal obligation to keep up-to-date with the list of banned/restricted substances as it changes and to ensure that these are not contained or only contained up to the allowed limit in any substances used for products or products supplied to BuyerUK Ltd. Please ensure you review this list online and ensure all relevant parties are made aware of the updated requirements.
In addition to the REACH candidate list there is an Authorisation list called Annex XIV, which contains substances, strategically selected from the above candidate list, that are not allowed to be placed on the market after the sunset date. The total number of substances on the authorisation list
Buyer requires from our suppliers that these substances are not contained in any product supplied to buyer
Buyer as a company must insist our suppliers do not use any of these substances in order to comply to each of our customer’s regulations. Buyer will carry out regular spot checks. Any trace of banned chemicals found in any product, or if any breach of this policy is identified, the supplier will be held liable and Buyer will reserve the right to debit back any costs. For continued non-compliance Buyer reserves the right to terminate their business relationship with the supplier. We will also ensure that the industry is made aware of your non-compliance. We should flow chemical management policy
If you do not know which chemicals/substances are contained in the articles you sell to us, you need to go back in your supply chain to obtain the requested information. All reputable suppliers should be able to provide you with Chemical Datasheets on all products you purchase from them, so that you as a responsible supplier can ensure the products you are buying do not contain any of the listed Banned Substances.
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