Reach Compliance Declaration

It has been determined that the products we offer are classified as articles by this regulation (European Community Regulation, EC1907/2006).  As defined by REACH, an article is a finished product that “during production is given a special shape, surface, or design which determines its function to a greater degree than its chemical composition.” In general, an article is an object composed of one or more substances or preparations given a special shape, surface, or design. Furthermore, an article is understood to be as produced or imported.

Since no substances or preparations used in EFC WESCO articles are imported into the EU that would exceed the 1 tonne per year threshold, no registration requirement currently exists for our products.  Furthermore, we do not anticipate having to register any of our products in the future. None of our products contain any “substances of intended release”. Typically, our products do not release any substances into the environment. As far as we know, all of the substances that are components and raw materials used in our processes have been for registered for our uses by upstream suppliers in our supply chain.

We acknowledge our responsibility as an “actor” in the supply chain to provide information on the composition of articles we supply to you (Article 33), including confirming the absence or presence of any SVHC (Substance of Very High Concern) when they are present in amounts in excess of 0.1% weight by weight. At present, none of the items we supply to you contain any SVHC per the latest candidate list or Annex 14 in concentrations above .1% weight by weight utilizing the mass balance method.

Since our products are very similar in composition across product series we will provide a summary of the parts that we have supplied to you by those product series, upon request. REACH does not require a full content disclosure and preserves the producer’s rights to trade secrets.

It is our intention to comply with the spirit of the REACH directive as well as the letter of the law. To that end, we hired a competent and independent third party auditor, Tanzco Management Consulting LLC, to verify that we had taken all prudent actions and completed the due diligence to support all of the claims herein. Tanzco Management Consulting has provided a Letter of Assertion of our REACH compliance based on a review of our production and technical records and on-site audits of our manufacturing processes completed in April and May 2009. A copy of that letter is available upon request. 

As you are aware this is an enormous undertaking for any manufacturer. Each month, new information, guidance, and interpretations become available. We make and will make every effort to remain current with any requirements that become incumbent on us and have subscribed to Tanzco’s update services as part of our efforts to remain current.

For more information please contact Angela or Jay at efc@filmcapacitors.com