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REACH (Registration, Authorisation and Restriction of Chemicals)

The European Regulation 1907/2006 "REACH" (Registration, Evaluation, Authorisation and Restriction of Chemicals) concerns chemical substances and entered into force in the European Union (EU) on 1st June 2007. The objective of the REACH regulation is to "improve the protection of human health and the environment from the risks that can be posed by chemicals". To achieve this objective, new statutory obligations apply to all parties involved in the supply chain. In other words, the manufacturer, the importer, the blender and the downstream user of a chemical substance each have specific obligations under the REACH regulation.
Obligations as manufacturer, importer or blender:
Chemical substances must be registered before any manufacture or import into the European Union (EU) if volumes exceed 1 (one) tonne per year. For substances already present on the European market transitional provisions have been set within REACH. In order to take advantage of these transitional provisions manufacturers and importers were required to pre-register their substances before 1st December, 2008. For pre-registered substances deadlines for registrations are 30th November 2010, 31st May 2013 or 31st May 2018 depending on manufactured or imported tonnages and hazards of each substance.
All substances produced (or imported) by TOTAL LUBRIFIANTS and for which the deadlines of 30th November, 2010 and 31st May, 2013 apply have been registered. For substances which are neither produced nor imported by TOTAL LUBRIFIANTS we have obtained confirmation from our suppliers that registration has been made in accordance with the above mentioned deadlines. Therefore we can guarantee that the products we sell to you are REACH compliant.
A REACH registration number is assigned for each substance and each legal entity: these registration numbers will be communicated by TOTAL LUBRIFIANTS in section 3 of the SDSs as they become available.
Should a decision be made by one of our suppliers or ourselves not to register a particular substance for the 31st May 2018 deadline or not to support a particular usage for this substance we would inform you of this decision without delay.
Classification changes may occur as a consequence of REACH registrations. These changes will be taken into account without delay in a new version of the safety data sheet.
As described in the Authorisation process of the REACH regulation the European Chemicals Agency (ECHA) establishes the candidate list of Substances of Very High Concern (SVHC). Inclusion of a substance on the candidate list may result in a need for an Authorisation at a later time, but it does not create any immediate limitation on the use of the substance.
Substances that are on the candidate list of SVHC and present in TOTAL LUBRIFIANTS products above the regulatory threshold of 0.1% wt will be communicated via the section 3 of the Safety Data Sheet. When ECHA publishes a new update of the SVHC candidate list TOTAL LUBRIFIANTS commits to update impacted product
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SDSs without delay from the date of list publication or reception of relevant supplier's information. These updated
SDSs will be published without undue delay.
Furthermore we can confirm that products supplied to you by TOTAL LUBRIFIANTS do not contain substances from annex XIV of the REACH regulation (Authorisation list).
Obligations as downstream user:
Registration of substances requires gathering information of the existing risks occurring during use as a
substance or as part of a mixture. Risk analysis is twofold: exposure to humans and impact on the environment.
This information must then be included in the substance or mixture Safety Data Sheet to ensure correct information
is provided to all parties throughout the supply chain.
A lubricant industry working group consisting of ATIEL members (Technical Association of the European
Lubricants Industry) and ATC members (Technical Committee of the Petroleum Additives Industry in Europe) was
established to develop generic exposure scenarios (GES) for known lubricant end uses. This information on GES and covered uses is available on the following web site: http://www.atiel.org/reach/endusers. If however you are unable to identify your specific use please inform us.
Should you require further information, please do not hesitate to contact the undersigned.

 

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