Summary and positioning according to the activities and analyses by the REACH working group. Valid for SUSPA® GmbH in Altdorf and Sulzbach as well as SUSPA®-Bor:
- SUSPA® does not manufacture any substances or preparations.
- SUSPA® does not import any substances or preparations from outside the EU.
- Nearly all of the procured auxiliary and operating materials (A&O) are preparations within the sense of REACH. A few auxiliary and operating materials are substances that are essentially used for laboratory requirements.
- SUSPA® procures PRODUCTS from within and outside of the EU from
- which nothing is intended to be released. For their part, these procured PRODUCTS become part of the PRODUCTS produced by SUSPA®.
- For its part, SUSPA® manufactures PRODUCTS from which nothing is intended to be released.
SUSPA® is thus a downstream user in the sense of the REACH regulation for almost all of the substances to be considered.
According to the current status of examination, there are no registration requirements for SUSPA® GmbH with locations in Altdorf and Sulzbach as well as the location of Bor in the Czech Republic!
SUSPA® activities related to registration:
SUSPA® is dependent on the upstream supplier making the necessary substance registrations. For their part, the SUSPA® suppliers are usually also "only" product manufacturers or preparers and usually do not have to register themselves.
As a downstream user, SUSPA® called on select suppliers of preparations (usually with annual delivery quantities > 200 kg) during the pre-registration phase to ensure the pre-registration status or the registration status.
SUSPA® activities relating to the substances of the REACH candidate list (SVHC):
SUSPA® complies with the information requirements regarding substances of the candidate list (SVHC = Substances of Very High Concern) required in article 33 of the REACH regulation. This requires a continuous observation process, since the candidate list is currently growing steadily.
SUSPA® is also dependent on active information from the suppliers with respect to the SVHC.
The REACH regulation itself requires all of our suppliers to actively inform us if SVHC are contained in the purchased products with a weight proportion greater than 0.1%.
New suppliers are obliged to comply with the REACH requirements by means of the SUSPA® quality assurance agreement.
Furthermore, SUSPA® requires REACH confirmations from the suppliers for new procured products as part of the supplier quality planning.
If material data is maintained via the IMDS (International Material Data System) (e.g. all automotive products), the suppliers have to specify the pure substances and therefore also the SVHC in the IMDS. Based on this information, SUSPA is informed whether any SVHC are contained and can check whether SVHC are present in the manufactured items with a weight proportion greater than 0.1%.
To this day, SUSPA® has no information that SVHC with a weight proportion > 0.1% are present in the products made by SUSPA®.
SUSPA® does not currently have to meet notification requirements to the ECHA according to article 7(2) of the REACH regulation, since the products made by SUSPA® do not contain any substances subject to reporting (SVHC) that exceed a weight proportion of 0.1% in the product and are used in an annual quantity greater than 1 ton/year at SUSPA®.
Altdorf, on June 23, 2017