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March 17, 2017
To: All Concerned Customers of Johnson Matthey Noble Metals, NA
From: William Scilingo Operations Director — Noble Metals, NA West Chester, PA
Re: Compliance to EU Regulation regarding Registration, Evaluation and Authorization of Chemicals (REACH)
We have reviewed the initial EU REACH Regulation (EC) No. 1907/2006 together with its amending Regulations and Corrigenda. We are complying as follows:
The REACH Regulation specifically requires that substances imported into the EU/EEA are registered where these fall in scope of the manufacture and/or import quantity thresholds, and are not otherwise exempted. We as manufacturers already have in place pre-registration / registration arrangements for such substances in our products which we directly import into the EU under our name (where individual substance quantities exceed the applicable tonnage threshold).
It is our understanding that products categorized as articles are exempt from registration / notification duties provided they do not intentionally release substances during use, and they do not contain designated Substances of Very High Concern (SVHC) on the REACH Annex XV Candidate List for Authorization. The articles that JMI manufacturers meet these exemptions.
As indicated above, none of the products we place on the market contains a substance designated as being of very high concern (SVHC) within the scope of the Regulation, and therefore we do not foresee that the supplies of any products supplied are likely to be affected by the Authorization title of REACH. We will continue to monitor SVHC substances on a regular basis.
As always, we will be glad to provide our customers with support in relation to any specific questions they may have regarding our products to assist their exporting efforts.
Operations Director -- Noble Metals, NA
(Candidate List for Authorization sub-site available at http://echa.europa.eu/web/guest/candidate-list-table)
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