REACH is a new European Union regulation concerning the Registration, Evaluation, Authorization and restriction of CHemicals.  The regulation came into force on 1st June 2007. REACH replaces numerous EU laws related to chemicals and is complementary to other environmental and safety legislation.

According to REACH, EU manufacturers or importers concerned have to provide registration dossier, indicating the identity of the substances, classification and labeling, guidance on safe use etc.

(a) EU manufacturers and importers; and
(b) Non-EU manufacturers cannot register but they can appoint an Only Representative (OR) for registration.  An OR is a natural person or a legal entity established in the EU that has sufficient background in fulfilling the REACH obligations of importers (if applicable) who would then become Downstream Users.

According to REACH, all EU-based manufacturers, importers or Only Representative established in the EU appointed by the non EU-based manufacturers are responsible for registration.

(a) Companies who do not pre-register before the deadlines will lose the benefit from extended registration deadlines. i.e., until 30 November 2010, 31 May 2013 or 31 May 2018, depending on the manufactured or imported annual volume (and characteristics) of substances.

(b) All phase-in substances in quantities more than 1 tonne per year should be pre-registered to enjoy the phase-in period benefit prior to full registration requirements.  If not pre-registered, full registration will be required before substance is manufactured and/or imported into the EU.

In the case of a first-time manufacturer or importer who manufactures or imports a substance in quantities of 1 tonne or more per year for the first time after the pre-registration deadline (1 December 2008) has passed, the manufacturer or importer can still benefit from the extended registration deadlines for phase-in substances even though he did not pre-register within the deadline for pre-registration.

For first-time manufacturers or importers of a substance in quantities of 1 tonne or more per year must pre-register within six months after first manufacture or import, and not later than 12 months before the relevant deadline for registration.

Our products contain ink and toner that are classified as "preparation" under REACH. Certain substances within the preparations are subject to pre-registration.

UTec have already put in place an Only Representative (OR) in EU to handle the pre-registration of substances. To comply with the REACH Regulation, we will record our customers (EU importers) as Downstream Users of our OR. Our customers do not need to register the substances again.

According to our evaluation there is no problem since we have already completed the pre-registration for the substances contained in our inks and toner in accordance with the requirements of REACH. 

There is an independent project team that is responsible for managing REACH compliance for UTec products.  The team has completed the pre-registration process and has a full plan for carrying out registration for substances in phases according to our assessment of export quantities or to seek suppliers who have fulfilled the registration requirement.  We will closely monitor the latest development of REACH and continue to fulfill the requirements.

REACH does not require registration of imported substances to EU in quantities of less than 1 tonne/year; however, if there is a request from our customers to provide information of substances for their use of registration, we will provide our customers with our registration numbers or the registration numbers provided by our suppliers within 3 months.

You can contact our sales representatives or send your enquiries to csd3@utec.com.mo.