Registration - Evaluation - Authorisation of Chemicals (REACh)

Safe Use of Substances along the Supply Chain

The idea of sustainability is deeply anchored in our company's philosophy: ROLEC thinks,
deals and feels strategically, passionately and environmentally aware! The following also
applies to us: Chemicals should generally be manufactured and used in such a way that
risks to human health and the environment are kept to an absolute minimum.
The European Union (EU) enforced this with the so-called REACh regulation on 01.06.2007.
It is based on the principle of personal responsibility of all companies that import, produce
and work with chemicals. They are responsible for guaranteeing the safe handling of their
substances and preparations. They are obliged to register the substances used, to collect
the necessary data and to pass this on along the supply chain.
Distributors of articles are only required to supply information if articles* which are imported
from outside the EU contain substances from the candidate list published by the ECHA
(European Chemicals Agency, Helsinki) in a concentration of more than 0.1% (w/w)
(Article 33).
(*Here an article is an object which during production is given a special shape, surface or
design which determines its function to a greater degree than does its chemical
composition.)

REACh and its Relevance to ROLEC

Rolec Gehäuse-Systeme GmbH is regarded, according to the REACh regulation, to be a
"downstream user" and "distributor of articles"; so there is no obligation to register.
Substances are not released from our products. For this reason Article 7, paragraph 1 of the
regulation is not applicable; of course we willingly and conscientiously fulfil our obligation to
provide information as a "distributor of articles" (Article 33 of the REACh regulation).
The substances and preparations we use (varnish, powder lacquer, adhesives, coolants and
lubricants in our production) are purchased solely within the EU. Customers who would like
to obtain these substances for repairs, for example, or for their own production will receive
the appropriate material safety data sheets from our suppliers in accordance with REACh.
Naturally we ensure that all products purchased outside of the EU (components and
assemblies) are checked for possible traces of substances from the candidate list. If any
were found to be contained in critical amounts (>0,1 % (w/w), we would immediately inform
all parties involved.

Pre-suppliers and REACh

The REACh regulation means "No data - no market!"
For Rolec that means: Our suppliers must be aware of the fact that we can only accept
goods from them if their products have been checked in accordance with REACh and they
are able to supply us with the necessary data.
It goes without saying that we also expect our suppliers who trade outside of the EU -
whether as importer or manufacturer - that they have acted accordingly within the
appropriate time frame in order to meet the requirements.
All suppliers based outside of the EU have been urged to check the substance compositions
and preparations concerning our products for traces of substances included in the candidate
list and to replace them where necessary. So far the latter has not been necessary; none of
our products has had to be changed in its composition due to the REACh regulation.
REACh constitutes a "living system" and so it will be constantly expanded. Likewise we will
also continue to see to the safety of substances used by us. For this reason REACh is
naturally firmly integrated in all of our processes.