I don't think I agree.
The EU kept telling companies to work together and collaborate, so that
the registration burden is smaller. The way I understand it:
If Resin XYZ is made by two or three companies with the same chemical
structure, only one of them needs to register it, although each of them
could register it. Then if further testing etc needs to be done later
on hazardous properties..., They can work together and share the costs
of that further testing. If they each register it, they will probably
each have to do the testing.
If the material is a proprietary substance only used by you, then it is
your responsibility to register it, if over the 1 tonne limit.
In Bev's case, if they are the only ones that use that particular liquid
crystal, then they would not need to register because the quantity isn't
high enough.
In Bill's case, if the materials used in the circuit boards are
proprietary to them, and all of the materials total together around one
tonne, then they don't need to register since all the chemical compounds
individually that make up a circuit board are under 1 tonne. But if the
materials are not unique to them, they should confirm that their
suppliers have arranged to register, or that their suppliers have
confirmed that someone else has registered them.
What a mess.
We need some Friday humour...
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of John Burke
Sent: June 27, 2008 1:09 PM
To: [log in to unmask]
Subject: Re: [TN] REACH
I believe that those limits are by the company (in this case RIM) not by
the material collectively over all shippers of the material
John Burke
(408) 515 4992
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Genny Gibbard
Sent: Friday, June 27, 2008 11:04 AM
To: [log in to unmask]
Subject: Re: [TN] REACH
Bev, have you pestered your liquid crystal supplier to ensure that THEY
have either registered or checked that someone else has registered or is
planning to register the substance, though?
You may not be their only company that uses this, and the total sales of
the substance from all uses and all suppliers might actually need to be
registered.
If they decide they don't want to register it, you could still be in
trouble.
At least that is my impression. I feel like I have a very poor
understanding of REACH.
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Bev Christian
Sent: June 27, 2008 11:57 AM
To: [log in to unmask]
Subject: Re: [TN] REACH
Bill,
I think this is important enough that I will answer you on-line. Perhaps
we will both learn something from the other public answers.
Perhaps my reading of REACH is wrong, but unless you are going to be
importing into the EU a particular substance in excess of one metric ton
you don't have any thing you have to do.
TechNetters,
Am I right or wrong? If I am, then RIM would have to import something
like 40 million Blackberries into the EU before we would need to
register the liquid crystal in the LCDs.
Bev
RIM
-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Bill Clark
Sent: Friday, June 27, 2008 1:37 PM
To: [log in to unmask]
Subject: [TN] REACH
Hello
I'm new to a small company that sells about a ton of circuit board
assemblies a year to European customers and I'm interested in discussing
how other small electronics manufacturers are managing REACH. If you'd
be willing to give me a couple of minutes, please send a note off line.
Thanks
Bill Clark
[log in to unmask]
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