Phone: (334) 792-0002 Toll Free: (800) 633-7550 Dothan, Alabama
Substances used to manufacture articles are exempted from the registration and pre-registration obligations under REACH. Articles may be exported to the EU without registration or pre-registration of the composing substances. Articles may however be affected by REACH in different ways, if any of these substances occur on the REACH Candidate List of very High Concerns lists or in REACH AnnexXVII; Restrictions to Marketing and use.
The Article Certification Service entails a verification of the fact that products exported to the EU are indeed articles, a check if any of the substances used occur in these lists or annexes, and a certification of the findings. In the case that any of the substances do occur on such a list or annex, advice will be given on the resulting obligations and on how to address these obligations.
The REACH Article Certification service is provided for Twitchell yarn and fabric products, which are manufactured in the Dothan, Alabama USA. Certification by Twitchell’s Only Representative, which is a ‘well established’ REACH consultant, prevents misunderstandings between non-EU suppliers and their EU based importers about the regulatory status of the products.
Twitchell Technical Products, LLC has provided the Only Representative with the following information of the articles.
· Trade names of all products exported to the EU
· All composing substances > 0,1% (names, CAS numbers and Einecs numbers)
· Where possible: also list substances <0,1%
· Which substances occur in which products (In addition Twitchell has provided the Only Representative a description of the articles.
The checks to be performed by Twitchell’s Only Representative will consist of the following:
· Are the products indeed ‘articles’ under REACH and are the composing substances therefore exempted from registration (Check against legislation and Technical Guidance Documents)
· Occurrence of substances on the Candidate list
· Occurrence of substances subject to authorisation (Annex XIV REACH)
· Occurrence of substances subject to restrictions on marketing and use. (Annex XVII REACH)
Twitchell Technical Products, LLC will provide a certificate of its findings for each product. The EU customers and the EU based importers can download the certificate directly from the Twitchell website.