Examples for substances in our product range: Reactive diluents for impregnating and trickling resins , hardeners or isocyanates for compounds
For the vast majority of our substances used we are not the manufacturer as defined under REACH. Therefore we have no obligations for registration. One exception are the polymers we manufacture ourselves, mainly resins which are used in our resins & varnishes or in our laminates. As per definition these polymers as such are not subject to registration under REACH. However, as far as necessary we are going to pre-register the relevant monomers and other reactants Whenever we use or formulate registered substances in our preparations or in articles and supply those to our customers we are a “downstream user ”. As far as we are importing substances from countries outside of the EU, we are going to register them through our own Only Representative Office or import them through the relevant Von Roll Company. We are expecting that the majority of the non-EU manufacturers will carry out the pre-registration/registration through Importers or Only Representatives in order to use the phase-in deadlines.-
Examples for preparations in our product range: Impregnating and trickle resins, Encapsulating and potting compounds, Solvent preparations (thinners)
Preparations (in future mixtures under GHS) are an important part of our product range. Preparations as such do not need to be registered. With the supply of preparations in the EU we can have 2 roles:
By formulating substances in our preparations we are only a downstream user under REACH. We have no obligations to register. We only need to make sure, that our suppliers of substances or the manufacturer have fulfilled their duties. We are going to ensure this by written inquiry, wherever possible..
As far as we are supplying preparations from one of our Non-EU Von Roll Companies into the EU, we are going to appoint our Von Roll Only Representative Office .This company will undertake all necessary pre-registration /registration activities under REACH. The customers in the EU will receive a written notification letter. With this, they become downstream users under the definition of REACH. Von Roll can continue to supply them directly from the Non-EU territory.
Examples for articles in our product range: Laminates, pressboards, enamelled wires, covered conductors, adhesive tapes, parts produced from composite materials , Pre-pregs, Mica tapes
Articles as such do not have to be registered.
Only if an intended release of a substance occurs during normal and foreseeable operating conditions then there is the obligation to register the released substance (only if it has not been registered already and if the threshold level of 1 to per annum will be exceeded). In our articles supplied there is usually no intended release of substances.
Starting from 2011 there is the obligation for a notification to ECHA, if Substances of Very High Concern from the “Candidate list”;or at a later point from the actual Annex XIV of the REACH-regulation , are contained at a level of more than 0,1% (weight/weight) in the article. These substances are called “SVHC”. Industrial and professional users need to be informed about such substances in articles.