REACH - 10-Steps Compliance Schedule by dtUV4Lx

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									REACH - AIG 8 step compliance schedule
as of : December 10th, 2007




  Step                                                    Activities


                 REACH AWARENESS
                 Request / define contact - data of REACH representative for your company and your
           1.0   suppliers
                     Develop an internal team chaired by the REACH representative to provide overall
           1.1       steer

           1.2       Identify own REACH Contact responsible for external communications



  1        1.3
           1.4
                     Identify all own legal entities impacted by REACH

                     Sending out of REACH - awareness letter to all suppliers / Tracking of supplier
                     responses

           1.5       Identify the respective REACH representative of the suppliers

                     Identify low, medium, high risk suppliers & define approach for handling each
           1.6       category
                 SUBSTANCE INVENTORY

           2.0   Identify all substances, preparations and articles falling under REACH


           2.1       Identify your roles under REACH

                     Recommended data for inventories, depending on the different roles

                       • Which substances/preparations the company purchases from inside EU
                         and for what purpose they are used?
           2.2         • For which substances/preparations the company purchases, SDS are


  2                      available / not available?
                       • Which substances/preparations the company imports and for what
                         purpose they are used?

           2.3       Check whether article list is complete for your business

                     Define/Distinguish whether the substances are in an article (Registration acc. to Art.
           2.4       6) or in a preparation in a container (Registration acc. to Art 7)
                     Which substances are intentionally released from an article that the company
           2.5       produces?
                     Which substances are intentionally released from an article that the company
           2.6       imports?
                 Declaration of Intent

           3.0   Identify all substances which will NOT be pre-registered by a supplier


           3.1       Send out letter to all of our suppliers requesting Declaration of Intent

                     Tracking of supplier responses on Pre-Registration and reassess suppliers' risk
           3.2
  3
                     category assigned in step 1.6
                Tracking of supplier responses on Pre-Registration and reassess suppliers' risk
    3.2
3
                category assigned in step 1.6
                Make sure that phase in substances are pre-registered by checking the pre-
    3.3         registration list published on 1 January 2009
                If substance is not included in the Pre-Registration list, DUs should seek a supplier
    3.4         that has Pre-Registered (ECHA can provide a list of alternative suppliers that have
                Pre-Registered, Art 28.5)

    3.5         Make sure that your non-EU supplier intends to establish an Only Representative


    4.0
4
           Inform your supplier about your use of the substances/preparations

                Start company-specific communication with your suppliers about your uses / Tracking
    4.1         of supplier responses
           Identify all substances / preparations where there is NO intention to register them and for
    5.0    your use

    5.1
5
                (Send out letter to all of our suppliers requesting Declaration of Intent, see 3.1)


    5.2         Tracking of supplier responses on intention to register your uses

                If supplier does not intend to register, define your next steps/counter-measures and
    5.3         communicate these to customers
           SVHCs

    6.0    Identify:

                Which articles & materials are likely to contain substances to be listed on the
    6.1         candidate list / Annex XIV (potential candidate list-substances)
                  Assess potential risk of supply chain disruption and evaluate potential counter
    6.2           measures
                Check if your identification of potential candidate list-substances is correct once the
    6.3         official candidate list is published
                Identify potential Substances of Very High Concern (candidate list-substances) in
    6.4         articles
                In your role as manufacturer or importer, Identify all substances in articles included in
    6.5
6
                the candidate list subject to notification requirements under Article 7(2)
                Ensure safe use information is available for SVHC in articles in accordance with
    6.6         Article 33(1) and be prepared to provide the data to DU
                Ensure safe use information is available for SVHC in articles in accordance with
    6.7         Article 33(2) and be prepared to provide the data to consumer within 45 days of
                request.

    6.8           Notify ECHA of substances contained in articles in accordance with Article 7(2)


    6.9         Identify imported substances on the candidate list on their own or in preparations

                Identify Substances on the candidate list on their own or in preparations used in the
    6.10        EU production process
                Make sure, that the identified substances are authorized for your use (Authorisation:
    6.11        in case of Annex XIV inclusion)
           Risk Management Measures

    7.0    Identify the Risk Management Measures in the SDS


    7.1         In your role as Downstream User, apply the RMM´s


7   7.2         In your role as manufacturer / importer, define the RMM´s

                  Supply safety data sheets for substances and preparations in accordance with
    7.3           article 31 compiled in accordance with Annex II including Chemical Safety Report
                  (CSR) where needed
7               Supply safety data sheets for substances and preparations in accordance with
    7.3         article 31 compiled in accordance with Annex II including Chemical Safety Report
                (CSR) where needed

    8.0
8
          Checking compliance with the Exposure Scenarios

              Verify if the conditions of your use and your customers uses comply to the
    8.1       prescription of your supplier
                                         2007                                          2008
  Timing           Month
                           Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr




                Plan
today - 01/08
                Progress
                Plan
today - 01/08
                Progress
                Plan
today - 01/08
                Progress
                Plan
today - 01/08
                Progress
                Plan
today - 02/08
                Progress
                Plan
today - 02/08
                Progress




                Plan
today - 04/08
                Progress
                Plan
today - 10/08
                Progress
                Plan
today - 10/08
                Progress
                Plan
today - 10/08
                Progress
                Plan
today - 10/08
                Progress
                Plan
today - 06/08
                Progress
                Plan
today - 10/08
                Progress
                Plan
today - 10/08
                Progress
                Plan
today - 10/08
                Progress




                Plan
01/08 - 06/08
                Progress
                Plan
01/08 - 07/08
01/08 - 07/08
                Progress
                Plan
01/09 - 04/09
                Progress
                Plan
01/09 - 04/09
                Progress

                Plan
  01/08 - ~
                Progress



                Plan
01/09 - 07/09
                Progress



                Plan
01/09 - 06/09
                Progress
                Plan
  01/09 - ~
                Progress
                Plan
  01/09 - ~
                Progress




                Plan
today - 12/08
                Progress
                Plan
  today - ~
                Progress
                Plan
  07/08 - ~
                Progress
                Plan
  07/08 - ~
                Progress
                Plan
  07/08 - ~

                Plan
  07/08 - ~
                Progress
                Plan
  07/08 - ~
                Progress
                Plan
06/11 - 01/12
                Progress
                Plan
  07/08 - ~
                Progress
                Plan
  07/08 - ~
                Progress
                Plan
  07/09 - ~
                Progress




                Plan
  today - ~
                Progress
                Plan
  today - ~
                Progress
                Plan
  09/08 - ~
09/08 - ~
            Progress




            Plan
today - ~
            Progress
        2008                                                                    2009


May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul
DEPENDING ON TONNAGE BAND

DEPENDING ON TONNAGE BAND
2009                                                                 2010


       Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct
CASE BY CASE
                                            2011


Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan
                          2012                                                            2013


Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr
        2013                                                                    2014


May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul
2014                                                                 2015


       Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct
                                            2016


Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan
                          2017                                                            2018


Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr
        2018


May   Jun   Jul   Aug   Sep   Oct   Nov   Dec
~

~

~

~


~

~




~

~

~




~

~

~
~
REACH - 8 Steps compliance schedule
as of : December 4th, 2007

NOTE this has only been updated to end of ste
 Steps                                                 Activities


                REACH AWARENESS
                Request / define contact - data of REACH representative for your company and your
          1.0   suppliers
                    Develop an internal Task Force Team chaired by the REACH representative to
          1.1       provide overall steer
                      Possible participants:
                      R&D
                      Purchasing
                      Planning
                      Overseas Sales Organisations
                      European Plants (EH&S)
                      Legal
                      Quality

          1.2       Identify own REACH responsible to overview the REACH deliverables

                      Under REACH, communication is required between the legal entities of each



  1
                      company. As one company very often has many different legal entities, the
                      communication can be difficult to manage.
                      Therefore it is recommended to appoint within one company one REACH-
                      representative, being the central contact point and responsible to manage the
                      company internal communication for all legal entities.
                      It is recommended that this person is located in Europe.

          1.3       Identify all own legal entities impacted by REACH

                    Sending out of REACH - awareness letter to all suppliers / Tracking of supplier
          1.4       responses

          1.5       Identify the respective REACH representative of the suppliers

                    Identify low, medium, high risk suppliers & define approach for handling each
          1.6       category
                      A preliminary message should be sent out as soon as possible to promote
                      awareness of REACH in the supply chain. An example has been developed
                      (awareness letter). It is recommended that this wording is used and that further
                      information is not requested at this early stage. Given the time pressure, your risk
                      assessment will need to be based on other factors than just feedback from the
                SUBSTANCE INVENTORY

          2.0   Identify all substances, preparations and articles falling under REACH


          2.1       Identify your roles under REACH


                      Please note that the level of details of the information to be collected may vary,
                      depending on the different roles that a company may play. The matrix in Guideline
                      3 gives an overview of these roles and the necessary information for each.


                    Recommended data for inventories, depending on the different roles
          Recommended data for inventories, depending on the different roles

            Downstream users must have a full understanding of what
            substances/preparations the company uses or imports and what are the
            substances in articles that the company produces or imports. Establishing an
            inventory will allow the company to determine:
          • Which substances/preparations the company purchases from inside EU and
            for what purpose they are used?
            Contact the chemicals suppliers to ensure that the substance/preparation will
            continue to be supplied (supported by pre-registration of the substance on its own
            or in preparations)
          • For which substances/preparations the company purchases, SDS are
            available / not available?
            DU must identify, apply, and, where suitable recommend, appropriate risk
            management measures, as indicated in the safety data sheet communicated to
            them, and information on risk management measures supplied to them in
            accordance with Article 32 REACH, or in their own chemical safety assessment
            (Article 37.5 REACH).
          • Which substances/preparations the company imports and for what
            purpose they are used?
    2.2
            Unless an “only representative of a non-community manufacturer” (that is, an
            exclusive representative), who will take over the obligations as an importer, has
            been appointed, you will have to comply with REACH obligations as an importer.
            (See also Step 5.3)


          • Which articles & materials are likely to contain substances to be listed on the
          candidate list / Annex XIV

             Be aware that a formal list of EU designated SVHC’s is not scheduled to be
             published until June 2009. Until there is an official list published, please use
             accepted industry listings of restricted substances or the working candidate list to
          • Which substances are intentionally released from an article that the
            company produces?

            For articles intentionally releasing substances, you will be obliged to register the
            substances released under certain conditions
            For substances present in the article, you will have to identify whether they are of



2
            very high concern. Under certain conditions, you will have to notify the Agency for
            such substances


          • Which substances are intentionally released from an article that the
    2.3     company imports?


            If no “only representative of a non-Community manufacturer” has been appointed,
            you will be obliged to register the substances intentionally released from the article
            that you import under certain conditions. You will also have to identify if the article
            contains substances of very high concern, and notify them to the Agency under
            certain conditions (See also Step 5.3)


          Define/Distinguish whether the substances are in an article (Registration acc. to Art.
    2.4   6) or in a preparation in a container (Registration acc. to Art 7)
                     Article producers/importers should pay attention under which provision of the
                     REACH regulation the intentionally released substance/substance in
                     preparation should be registered:
                     • If the substance that requires registration is considered as a substance
                     delivered in a container, the substance has to be registered according to
                     Article 6 REACH. Please note that the container itself may be considered as
                     an article according to Article 3.3 REACH.
                     • If the substance to be registered is considered as a substance in an article,
                     the substance requires registration according to Article 7.1 REACH (for the
                     definition of an article, please see Chapter 2 of the Guideline). “


    2.5       Check whether article list is complete for your business


                     The global Automotive Industry has identified that the only articles which are a
                     part of a vehicle (have to be imported into EU within a vehicle) and
                     intentionally release substances under normal or reasonably foreseeable
                     conditions of use are:
                     • Fragrance dispensers,
                     • Fire extinguishers,
                     • Windshield-washer fluid




    2.6            Confirm supplier intent to register your uses for all substances supplied.




                   If supplier does not intend to register, define your next steps/counter-measures
    2.7            and communicate these to customers



          Declaration of Intent

    3.0   Inform your supplier about your use of the substances/preparations


              Send out a declaration of intent including all important information to your supplier of
    3.1       substances and preparations / Tracking of supplier responses


3                If conformable with the Know-How protection of the company, the downstream user
                 should already during the pre-registration phase inform in written his suppliers of
                 substances or preparations about his use.
                 This will support the supplier in his later registration-process.
                 For reasons of know-how protection it is recommendable for the downstream user
                 not to explain the use too much in detail


    4.0   Identify all substances which will not be pre-registered by a supplier



              Sent out the declaration of Intend to all of our suppliers / Tracking of supplier
    4.1       responses
              Sent out the declaration of Intend to all of our suppliers / Tracking of supplier
    4.1       responses



              Make sure, that phase in substances are pre-registered by checking the pre-
    4.2       registration list published on January 1st, 2009

                On 1 January 2009 the agency publishes the list of pre-registered substances on
                its website (name, numbers, registration deadline).
                As a user of substances check that the substances used are included on this list; if



4
                not inform the agency (art. 28.5).


              If substance(s) are not listed on the Pre-Reg list, DU to notify ECHA for extended pre-
    4.3       registration




                Downstream user to notify ECHA his contact details and details of suppliers
                ECHA to publish name of substance(s) and provide on request contact details of
                DU to manufacturer / importer




          Identify all substances / preparations from inside EU OR which are imported from outside
    5.0   EU and have not already been registered for our use
              Sent out the "Declaration of Intend" to all of our suppliers / Tracking of supplier
    5.1       responses

    5.2       Make sure, that those substances are registered for that use by the suppliers



                Supplier has to confirm, that he will pre-register and has the intention to register.
                Supplier furthermore has to notify customer immediately if he will not register the
                substance for the respective use




5   5.3       Make sure, that your supplier has established an Only Representative
5
                 The major recommendation of the AIG is to ask the non-European suppliers to
                 establish an Only Representative within Europe. Regrettably this first priority can
                 not always be adopted. If for example suppliers don´t want to or are not able to
                 establish an Only Representative in Europe further options have to be considered
                 and could be prioritised as follows:
                 - Priority 1: Ask supplier to establish an Only Representative and to register
                 - Priority 2: Change your supplier or substitute the substance / preparation
                 - Priority 3: Register by yourselves on behalf of your supplier or ask a service
                 provider to act on behalf of you.
                 The order especially of priority 2 & 3 is not fix but depends on the company specific
                 policies and strategies.
          SVHCs

    6.0   Identify:




    6.1        SVHC in Articles




                 Already established substance reporting systems (e.g. IMDS, MACSI) can be used
                 for inventory. Prerequisite for a correct substance reporting is a continuously
                 updated SVHC-list (e.g. GADSL). In case of new SVHC, an update of the reported
                 substance information is necessary.

                 Pre-Condition is that IMDS reporting is complete!




    6.? NEW ROWIdentify all Substances of Very High Concern in articles subject to
6       notification requirements under Article 7 section 2



    6.2   Notify ECHA of substances contained in articles in accordance with Article 7, section 2



          NEW ROW AS above for newly imported substances.                   Substance imported for
    6.?   the first time that have not already been registered for your use must be notified before
          importing into EU.

    6.3        Imported SVHC (is this substance or preparation? Not articles?)

               SVHC used in the EU production process (is this substance or preparation? Not
    6.4        articles?)

    6.5        Compare candidate list / Annex XIV with result of identification

               Make sure, that those substances are registered/authorized for the use by the
    6.6        suppliers (Authorisation: in case of Annex 14 inclusion)

          NEW ROW Ensure safe use information is available for SVHC in articles in
    6.7   accordance with Article 33 and be prepared to provide the data to DU/consumer within 45
          days of request.
          NEW ROW Ensure safe use information is available for SVHC in articles in
    6.7   accordance with Article 33 and be prepared to provide the data to DU/consumer within 45
          days of request.


    6.7 NEW ROW Supply safety data sheets for with Annex II: preparations in
        accordance with article 31 compiled in accordance
                                                          substances and


          Risk Management Measures

    7.0   Identify the Risk Management Measures in the SDS


7   7.1
    7.2
              Define the RMM´s

              Apply The RMM´s


    8.0   Check the conditions described in the Exposure Scenarios


    8.1       Verify the conditions for your use and your customers uses



          In order to secure a continued supply of a substance on its own/in preparations for their
          use(s), downstream users (hereafter called “DU”), have to check whether the supplier will
          support their use(s) and include them in the substance registration dossier to be


8         submitted to the agency. DU may only use substances on their own/in preparations which
          have been registered for their use(s) after the registration deadline has passed. It is
          therefore in the interest of DU to communicate early with their suppliers with view to
          having their use(s) included in the supplier’s registration dossier.
          The supplier might be a downstream user, which, in turn, may decide either to carry out a
          registration by himself or to communicate the use(s) to his own supplier. The final actor of
          that chain is the manufacturer/importer of the substance/only representative of a non
          Community manufacturer who may finally carry out the registration obligations.
          (In the future, an IT-Tool will be available for communication up and down the supply
          chain.)




          Missing: Identify Substances which have not been / will not be authorized for our
          use?

          There is no mention in the 8 steps of the need for M/I's to generate Chemical
          Safety Reports (CSR's) for substances over 10tonnes/annum/manufacturer or
          importer. Article 14
dated to end of step 2
                                                                                      2007
            Main
                       Supporter   Recommended Tools AIG Reference      Month
         Responsible                                                            Jul


                                                                     Plan
                                                                     Progress
                                                                     Plan
                                                                     Progress




                                                                     Plan
                                                                     Progress
                                    Letter for REACH-
                                                        Annex B
                                        awareness




                                                                     Plan
                                                                     Progress
                                                                     Plan
                                                                     Progress
                                                                     Plan
                                                                     Progress
                                                                     Plan
                                                                     Progress




                                                                     Plan
                                                                     Progress
                                                                     Plan
                                                                     Progress




                                                                     Plan



                                                        Guideline
                                                            3
                                Progress


                   Guideline
                       3

                                Plan
                                Progress


  Inventory

                                Plan
                                Progress




                                Plan
                                Progress

                   Guideline
                       4




                                Plan

                   Guideline    Progress
                       3


                                Plan

                                Progress




                                Plan

                                Progress




                                Plan

                                Progress




List of Articles   Guidelines
                     7&8
List of Articles   Guidelines
                     7&8




                                Plan

                                Progress




                                Plan




                                Progress




                                Plan



                                Progress




                                Plan
                                Progress

                                Plan

                                Progress




                                Plan
                                Progress
                                Plan




                   Guideline
                       5
                                     Progress


                        Guideline
                                     Plan
                            5
                                     Progress




                                     Plan


                                     Progress




Declaration of Intend
          &
 Result of Inventory




                                     Plan
                                     Progress
                                     Plan
                                     Progress
                                     Plan
                                     Progress




                                     Plan

                        Guidelines
                          4&6
                                     Progress
                         Guidelines
                           4&6




                                      Plan
                                      Progress
                                      Plan




                                      Progress




  GADSL, Material
 Reporting Systems
  (IMDS, others...)




                         Guidelines
                          8, 9, 10
                                      Plan

                                      Progress


                                      Plan

                                      Progress

                                      Plan

                                      Progress

                                      Plan
                                      Progress
Results of Inventories                Plan
          &                           Progress
  Already existing                    Plan
 internal processes                   Progress
                                      Plan
                                      Progress
                                 Plan
                                 Progress
                                 Plan
                                 Progress
                                 Plan
                                 Progress
                                 Plan
                                 Progress
                                 Plan
                                 Progress


 Already existing    Guideline
internal processes       5
        2007                                                  2008


Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct
NOTE: TO END AT SAME TIME AS RESPONSE TO 2ND LETTER
                                            2009


Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan
ETTER
                          2010                                                            2011


Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr
        2011                                                                    2012


May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul
2012                                                                 2013


       Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct
                                            2014


Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan
                          2015                                                            2016


Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr
        2016                                                                    2017


May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul
2017                                                                 2018


       Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct
Nov   Dec
REACH - 8 Steps compliance schedule
as of : October 1st, 2007



                                                                                                                                                                                                         2007                                                  2008                                                                    2009                                                                    2010                                                                    2011
                                                                                                                       Main
 Steps                                                       Activities                                                           Supporter   Recommended Tools AIG Reference      Month
                                                                                                                    Responsible
                                                                                                                                                                                           Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec    Jan    Feb   Mar


                 REACH AWARENESS

                 Request / define contact - data of REACH representative for your company and your                                                                              Plan
           1.0   suppliers                                                                                                                                                      Progress
                            Develop an internal Task Force Team chaired by the REACH representative to                                                                          Plan
           1.1              provide overall steer                                                                                                                               Progress

                                 Possible participants:
                                 R&D
                                 Purchasing
                                 Planning
                                 Overseas Sales Organisations
                                 European Plants (EH&S)
                                 Legal
                                 Quality

                                                                                                                                                                                Plan
           1.2              Identify own REACH responsible to overview the REACH deliverables
                                                                                                                                                                                Progress



                                 Under REACH, communication is required between the legal entities of each
                                 company. As one company very often has many different legal entities, the                                     Letter for REACH-


  1
                                                                                                                                                                    Annex B
                                 communication can be difficult to manage.                                                                         awareness
                                 Therefore it is recommended to appoint within one company one REACH-
                                 representative, being the central contact point and responsible to manage
                                 the company internal communication for all legal entities.
                                 It is recommended that this person is located in Europe.



                                                                                                                                                                                Plan
           1.3              Identify all own legal entities impacted by REACH
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
                            Sending out of REACH - awareness letter to all suppliers / Tracking of supplier
           1.4              responses
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
           1.5              Identify the respective REACH representative of the suppliers
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
                            Identify low, medium, high risk suppliers & define approach for handling each
           1.6              category
                                                                                                                                                                                Progress

                                 A preliminary message should be sent out as soon as possible to promote
                                 awareness of REACH in the supply chain. An example has been developed
                                 (awareness letter). It is recommended that this wording is used and that
                                 further information is not requested at this early stage.

                 SUBSTANCE INVENTORY

                                                                                                                                                                                Plan
           2.0   Identify all substances, preparations and articles falling under REACH
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
           2.1              Identify your roles under REACH
                                                                                                                                                                                Progress

                                 Please note that the level of details of the information to be collected may
                                 vary, depending on the different roles that a company may play. The matrix
                                 in Guideline 3 gives an overview of these roles and the necessary
                                 information for each.

                                                                                                                                                                                Plan
                            Recommended data for inventories, depending on the different roles
                                                                                                                                                                                Progress
                                 Downstream users must have a full understanding of what
                                 substances/preparations the company uses or imports and what are the
                                 substances in articles that the company produces or imports. Establishing an
                                 inventory will allow the company to determine:                                                                                    Guideline
                                                                                                                                                                       3
                                                                                                                                                                                Plan
                            • Which substances/preparations the company purchases from inside EU and
                              for what purpose they are used?
                                                                                                                                                                                Progress


                                 Contact the chemicals suppliers to ensure that the substance/preparation
                                 will continue to be supplied (supported by pre-registration of the substance                                      Inventory
                                 on its own or in preparations)


                                                                                                                                                                                Plan
                            • For which substances/preparations the company purchases, SDS are
                              available / not available?
                                                                                                                                                                                Progress

                                 DU must identify, apply, and, where suitable recommend, appropriate risk
                                 management measures, as indicated in the safety data sheet communicated
                                 to them, and information on risk management measures supplied to them in
                                 accordance with Article 32 REACH, or in their own chemical safety
                                 assessment (Article 37.5 REACH).
           2.2
                                                                                                                                                                                Plan
                            • Which substances/preparations the company imports and for what
                              purpose they are used?
                                                                                                                                                                                Progress
                                                                                                                                                                   Guideline
                                 Unless an “only representative of a non-community manufacturer” (that is,
                                                                                                                                                                       4
                                 an exclusive representative), who will take over the obligations as an
                                 importer, has been appointed, you will have to comply with REACH
                                 obligations as an importer.
                                 (See also Step 5.3)

                            • Which articles & materials are likely to be listed on the candidate list /                                                                        Plan
                              Annex XIV                                                                                                                            Guideline    Progress
                                                                                                                                                                       3


  2                              Outline strategies for each – is a substitution necessary?
                                 Gather data to support authorisation for your use?

                            • Which substances are intentionally released from an article that the
                              company produces?
                                                                                                                                                                                Plan

                                                                                                                                                                                Progress

                                 For articles intentionally releasing substances, you will be obliged to register
                                 the substances released under certain conditions

                                 For substances present in the article, you will have to identify whether they
                                 are of very high concern. Under certain conditions, you will have to notify the
                                 Agency for such substances

                                                                                                                                                                                Plan
                            • Which substances are intentionally released from an article that the
           2.3                company imports?
                                                                                                                                                                                Progress


                                 If no “only representative of a non-Community manufacturer” has been
                                 appointed, you will be obliged to register the substances intentionally
                                 released from the article that you import under certain conditions. You will
                                 also have to identify if the article contains substances of very high concern,
                                 and notify them to the Agency under certain conditions (See also Step 5.3)


                                                                                                                                                                                Plan
                            Define/Distinguish whether the substances are in an article (Registration acc. to
           2.4              Art. 6) or in a preparation in a container (Registration acc. to Art 7)
                                                                                                                                                                                Progress




                                                                                                                                                List of Articles   Guidelines
                                                                                                                                                                     7&8




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     Page 106 of 120
REACH - 8 Steps compliance schedule
as of : October 1st, 2007



                                                                                                                                                                                                              2007                                                  2008                                                                    2009                                                                    2010                                                                    2011
                                                                                                                        Main
 Steps                                                       Activities                                                            Supporter   Recommended Tools AIG Reference          Month
                                                                                                                     Responsible
                                                                                                                                                                                                Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec    Jan    Feb   Mar


                                            Article producers/importers should pay attention under which
                                            provision of the REACH regulation the intentionally released
                                            substance/substance in preparation should be registered:                                              List of Articles      Guidelines
                                            • If the substance that requires registration is considered as a                                                              7&8
                                            substance delivered in a container, the substance has to be
                                            registered according to Article 6 REACH. Please note that the
                                            container itself may be considered as an article according to Article
                                            3.3 REACH.
                                            • If the substance to be registered is considered as a substance in
                                            an article, the substance requires registration according to Article
                                            7.1 REACH (for the definition of an article, please see Chapter 2
                                            of the Guideline). “

                                                                                                                                                                                     Plan
           2.5               Check whether article list is complete for your business
                                                                                                                                                                                     Progress


                                            The global Automotive Industry has identified that the only articles
                                            which are a part of a vehicle (have to be imported into EU within a
                                            vehicle) and intentionally release substances under normal or
                                            reasonably foreseeable conditions of use are:
                                            • Fragrance dispensers,
                                            • Fire extinguishers,
                                            • Windshield-washer fluid


  1        2.6                         Make sure, that those substances are registered for that use by the
                                       suppliers
                                                                                                                                                                                     Plan

                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           2.7                         If substances are not registered, ask supplier for registration
                                                                                                                                                                                     Progress

                 Declaration of Intent

                                                                                                                                                                                     Plan
           3.0   Inform your supplier about your use of the substances/preparations
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
                             Send out a declaration of intent including all important information to your supplier


  3        3.1               of substances and preparations / Tracking of supplier responses


                                  If conformable with the Know-How protection of the company, the
                                                                                                                                                                                     Progress



                                  downstream user should already during the pre-registration phase inform in
                                  written his suppliers of substances or preparations about his use.
                                  This will support the supplier in his later registration-process.
                                  For reasons of know-how protection it is recommendable for the
                                  downstream user not to explain the use too much in detail

                                                                                                                                                                                     Plan
           4.0   Identify all substances which will not be pre-registered by a supplier
                                                                                                                                                                                     Progress
                                                                                                                                                                        Guideline
                             Sent out the declaration of Intend to all of our suppliers / Tracking of supplier                                                              5        Plan
           4.1               responses
                                                                                                                                                                                     Progress

                             Make sure, that phase in substances are pre-registered by checking the pre-                                                                             Plan
           4.2               registration list published on January 1st, 2009
                                                                                                                                                                                     Progress



  4                               On 1 January 2009 the agency publishes the list of pre-registered
                                  substances on its website (name, numbers, registration deadline).
                                  As a user of substances check that the substances used are included on
                                  this list; if not inform the agency (art. 28.5).

                                                                                                                                                                                     Plan
                             If substance(s) are not listed on the Pre-Reg list, DU to notify ECHA for extended
           4.3               pre-registration
                                                                                                                                                                                     Progress

                                  Downstream user to notify ECHA his contact details and details of suppliers                                  Declaration of Intend
                                  ECHA to publish name of substance(s) and provide on request contact                                                    &
                                  details of DU to manufacturer / importer                                                                      Result of Inventory

                                                                                                                                                                                     Plan
                 Identify all substances / preparations from inside EU OR which are imported from outside
           5.0   EU and have not already been registered for our use
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
                             Sent out the "Declaration of Intend" to all of our suppliers / Tracking of supplier
           5.1               responses
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           5.2               Make sure, that those substances are registered for that use by the suppliers
                                                                                                                                                                                     Progress


                                  Supplier has to confirm, that he will pre-register and has the intention to
                                  register. Supplier furthermore has to notify customer immediately if he will


  5        5.3
                                  not register the substance for the respective use



                             Make sure, that your supplier has established an Only Representative
                                                                                                                                                                        Guidelines
                                                                                                                                                                          4&6
                                                                                                                                                                                     Plan

                                                                                                                                                                                     Progress


                                  The major recommendation of the AIG is to ask the non-European suppliers
                                  to establish an Only Representative within Europe. Regrettably this first
                                  priority can not always be adopted. If for example suppliers don´t want to or
                                  are not able to establish an Only Representative in Europe further options
                                  have to be considered and could be prioritised as follows:
                                  - Priority 1: Ask supplier to establish an Only Representative and to register
                                  - Priority 2: Change your supplier or substitute the substance / preparation
                                  - Priority 3: Register by yourselves on behalf of your supplier or ask a service
                                  provider to act on behalf of you.
                                  The order especially of priority 2 & 3 is not fix but depends on the company
                                  specific policies and strategies.


                 SVHCs
                                                                                                                                                                                     Plan
           6.0   Identify:
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           6.1               SVHC in Articles
                                                                                                                                                                                     Progress

                                  Already established substance reporting systems (e.g. IMDS, MACSI) can                                         GADSL, Material
                                  be used for inventory. Prerequisite for a correct substance reporting is a                                    Reporting Systems
                                  continuously updated SVHC-list (e.g. GADSL). In case of new SVHC, an                                           (IMDS, others...)
                                  update of the reported substance information is necessary.

                                  Pre-Condition is that IMDS reporting is complete!



  6        6.2                    If necessary, do substance notification                                                                                               Guidelines
                                                                                                                                                                         8, 9, 10
                                                                                                                                                                                     Plan

                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           6.3               Imported SVHC
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           6.4               SVHC used in the EU production process                                                                            Results of Inventories
                                                                                                                                                         &                           Progress
                                                                                                                                                 Already existing                    Plan
           6.5               Compare candidate list / Annex XIV with result of identification                                                   internal processes
                                                                                                                                                                                     Progress

                             Make sure, that those substances are registered/authorized for the use by the                                                                           Plan
           6.6               suppliers (Authorisation: in case of Annex 14 inclusion)
                                                                                                                                                                                     Progress

                 Risk Management Measures
                                                                                                                                                                                     Plan
           7.0   Identify the Risk Management Measures in the SDS
                                                                                                                                                                                     Progress


  7                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       Page 107 of 120
REACH - 8 Steps compliance schedule
as of : October 1st, 2007



                                                                                                                                                                                                       2007                                                  2008                                                                    2009                                                                    2010                                                                    2011
                                                                                                                     Main
 Steps                                                     Activities                                                           Supporter   Recommended Tools AIG Reference      Month
                                                                                                                  Responsible
                                                                                                                                                                                         Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec    Jan    Feb   Mar



  7        7.1              Define the RMM´s
                                                                                                                                                                              Plan

                                                                                                                                                                              Progress

                                                                                                                                                                              Plan
           7.2              Apply The RMM´s
                                                                                                                                                                              Progress

                                                                                                                                                                              Plan
           8.0   Check the conditions described in the Exposure Scenarios
                                                                                                                                                                              Progress

                                                                                                                                                                              Plan
           8.1              Verify the conditions for your use and your customers uses
                                                                                                                                                                              Progress
                                                                                                                                               Already existing   Guideline
                                                                                                                                             internal processes       5


                 In order to secure a continued supply of a substance on its own/in preparations for their



  8
                 use(s), downstream users (hereafter called “DU”), have to check whether the supplier will
                 support their use(s) and include them in the substance registration dossier to be submitted
                 to the agency. DU may only use substances on their own/in preparations which have been
                 registered for their use(s) after the registration deadline has passed. It is therefore in the
                 interest of DU to communicate early with their suppliers with view to having their use(s)
                 included in the supplier’s registration dossier.


  1              The supplier might be a downstream user, which, in turn, may decide either to carry out a
                 registration by himself or to communicate the use(s) to his own supplier. The final actor of
                 that chain is the manufacturer/importer of the substance/only representative of a non
                 Community manufacturer who may finally carry out the registration obligations.
                 (In the future, an IT-Tool will be available for communication up and down the supply
                 chain.)




                 Missing: Identify Substances which have not been / will not be authorized for our
                 use?




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   Page 108 of 120
REACH - 8 Steps compliance schedule
as of : October 1st, 2007



                                                                                                                                                                                                         2012                                                                    2013                                                                    2014                                                                    2015                                                                    2016
                                                                                                                       Main
 Steps                                                       Activities                                                           Supporter   Recommended Tools AIG Reference      Month
                                                                                                                    Responsible
                                                                                                                                                                                           Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep    Oct    Nov   Dec


                 REACH AWARENESS

                 Request / define contact - data of REACH representative for your company and your                                                                              Plan
           1.0   suppliers                                                                                                                                                      Progress
                            Develop an internal Task Force Team chaired by the REACH representative to                                                                          Plan
           1.1              provide overall steer                                                                                                                               Progress

                                 Possible participants:
                                 R&D
                                 Purchasing
                                 Planning
                                 Overseas Sales Organisations
                                 European Plants (EH&S)
                                 Legal
                                 Quality

                                                                                                                                                                                Plan
           1.2              Identify own REACH responsible to overview the REACH deliverables
                                                                                                                                                                                Progress



                                 Under REACH, communication is required between the legal entities of each
                                 company. As one company very often has many different legal entities, the                                     Letter for REACH-


  1
                                                                                                                                                                    Annex B
                                 communication can be difficult to manage.                                                                         awareness
                                 Therefore it is recommended to appoint within one company one REACH-
                                 representative, being the central contact point and responsible to manage
                                 the company internal communication for all legal entities.
                                 It is recommended that this person is located in Europe.



                                                                                                                                                                                Plan
           1.3              Identify all own legal entities impacted by REACH
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
                            Sending out of REACH - awareness letter to all suppliers / Tracking of supplier
           1.4              responses
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
           1.5              Identify the respective REACH representative of the suppliers
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
                            Identify low, medium, high risk suppliers & define approach for handling each
           1.6              category
                                                                                                                                                                                Progress

                                 A preliminary message should be sent out as soon as possible to promote
                                 awareness of REACH in the supply chain. An example has been developed
                                 (awareness letter). It is recommended that this wording is used and that
                                 further information is not requested at this early stage.

                 SUBSTANCE INVENTORY

                                                                                                                                                                                Plan
           2.0   Identify all substances, preparations and articles falling under REACH
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
           2.1              Identify your roles under REACH
                                                                                                                                                                                Progress

                                 Please note that the level of details of the information to be collected may
                                 vary, depending on the different roles that a company may play. The matrix
                                 in Guideline 3 gives an overview of these roles and the necessary
                                 information for each.

                                                                                                                                                                                Plan
                            Recommended data for inventories, depending on the different roles
                                                                                                                                                                                Progress
                                 Downstream users must have a full understanding of what
                                 substances/preparations the company uses or imports and what are the
                                 substances in articles that the company produces or imports. Establishing an
                                 inventory will allow the company to determine:                                                                                    Guideline
                                                                                                                                                                       3
                                                                                                                                                                                Plan
                            • Which substances/preparations the company purchases from inside EU and
                              for what purpose they are used?
                                                                                                                                                                                Progress


                                 Contact the chemicals suppliers to ensure that the substance/preparation
                                 will continue to be supplied (supported by pre-registration of the substance                                      Inventory
                                 on its own or in preparations)


                                                                                                                                                                                Plan
                            • For which substances/preparations the company purchases, SDS are
                              available / not available?
                                                                                                                                                                                Progress

                                 DU must identify, apply, and, where suitable recommend, appropriate risk
                                 management measures, as indicated in the safety data sheet communicated
                                 to them, and information on risk management measures supplied to them in
                                 accordance with Article 32 REACH, or in their own chemical safety
                                 assessment (Article 37.5 REACH).
           2.2
                                                                                                                                                                                Plan
                            • Which substances/preparations the company imports and for what
                              purpose they are used?
                                                                                                                                                                                Progress
                                                                                                                                                                   Guideline
                                 Unless an “only representative of a non-community manufacturer” (that is,
                                                                                                                                                                       4
                                 an exclusive representative), who will take over the obligations as an
                                 importer, has been appointed, you will have to comply with REACH
                                 obligations as an importer.
                                 (See also Step 5.3)

                            • Which articles & materials are likely to be listed on the candidate list /                                                                        Plan
                              Annex XIV                                                                                                                            Guideline    Progress
                                                                                                                                                                       3


  2                              Outline strategies for each – is a substitution necessary?
                                 Gather data to support authorisation for your use?

                            • Which substances are intentionally released from an article that the
                              company produces?
                                                                                                                                                                                Plan

                                                                                                                                                                                Progress

                                 For articles intentionally releasing substances, you will be obliged to register
                                 the substances released under certain conditions

                                 For substances present in the article, you will have to identify whether they
                                 are of very high concern. Under certain conditions, you will have to notify the
                                 Agency for such substances

                                                                                                                                                                                Plan
                            • Which substances are intentionally released from an article that the
           2.3                company imports?
                                                                                                                                                                                Progress


                                 If no “only representative of a non-Community manufacturer” has been
                                 appointed, you will be obliged to register the substances intentionally
                                 released from the article that you import under certain conditions. You will
                                 also have to identify if the article contains substances of very high concern,
                                 and notify them to the Agency under certain conditions (See also Step 5.3)


                                                                                                                                                                                Plan
                            Define/Distinguish whether the substances are in an article (Registration acc. to
           2.4              Art. 6) or in a preparation in a container (Registration acc. to Art 7)
                                                                                                                                                                                Progress




                                                                                                                                                List of Articles   Guidelines
                                                                                                                                                                     7&8




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     Page 109 of 120
REACH - 8 Steps compliance schedule
as of : October 1st, 2007



                                                                                                                                                                                                              2012                                                                    2013                                                                    2014                                                                    2015                                                                    2016
                                                                                                                        Main
 Steps                                                       Activities                                                            Supporter   Recommended Tools AIG Reference          Month
                                                                                                                     Responsible
                                                                                                                                                                                                Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep    Oct    Nov   Dec


                 REACH AWARENESS
                               Article producers/importers should pay attention under which
                                            provision of the REACH regulation the intentionally released
                                            substance/substance in preparation should be registered:                                              List of Articles      Guidelines
                                            • If the substance that requires registration is considered as a                                                              7&8
                                            substance delivered in a container, the substance has to be
                                            registered according to Article 6 REACH. Please note that the
                                            container itself may be considered as an article according to Article
                                            3.3 REACH.
                                            • If the substance to be registered is considered as a substance in
                                            an article, the substance requires registration according to Article
                                            7.1 REACH (for the definition of an article, please see Chapter 2
                                            of the Guideline). “

                                                                                                                                                                                     Plan
           2.5               Check whether article list is complete for your business
                                                                                                                                                                                     Progress


                                            The global Automotive Industry has identified that the only articles
                                            which are a part of a vehicle (have to be imported into EU within a
                                            vehicle) and intentionally release substances under normal or
                                            reasonably foreseeable conditions of use are:
                                            • Fragrance dispensers,
                                            • Fire extinguishers,
                                            • Windshield-washer fluid


  1        2.6                         Make sure, that those substances are registered for that use by the
                                       suppliers
                                                                                                                                                                                     Plan

                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           2.7                         If substances are not registered, ask supplier for registration
                                                                                                                                                                                     Progress

                 Declaration of Intent

                                                                                                                                                                                     Plan
           3.0   Inform your supplier about your use of the substances/preparations
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
                             Send out a declaration of intent including all important information to your supplier


  3        3.1               of substances and preparations / Tracking of supplier responses


                                  If conformable with the Know-How protection of the company, the
                                                                                                                                                                                     Progress



                                  downstream user should already during the pre-registration phase inform in
                                  written his suppliers of substances or preparations about his use.
                                  This will support the supplier in his later registration-process.
                                  For reasons of know-how protection it is recommendable for the
                                  downstream user not to explain the use too much in detail

                                                                                                                                                                                     Plan
           4.0   Identify all substances which will not be pre-registered by a supplier
                                                                                                                                                                                     Progress
                                                                                                                                                                        Guideline
                             Sent out the declaration of Intend to all of our suppliers / Tracking of supplier                                                              5        Plan
           4.1               responses
                                                                                                                                                                                     Progress

                             Make sure, that phase in substances are pre-registered by checking the pre-                                                                             Plan
           4.2               registration list published on January 1st, 2009
                                                                                                                                                                                     Progress



  4                               On 1 January 2009 the agency publishes the list of pre-registered
                                  substances on its website (name, numbers, registration deadline).
                                  As a user of substances check that the substances used are included on
                                  this list; if not inform the agency (art. 28.5).

                                                                                                                                                                                     Plan
                             If substance(s) are not listed on the Pre-Reg list, DU to notify ECHA for extended
           4.3               pre-registration
                                                                                                                                                                                     Progress

                                  Downstream user to notify ECHA his contact details and details of suppliers                                  Declaration of Intend
                                  ECHA to publish name of substance(s) and provide on request contact                                                    &
                                  details of DU to manufacturer / importer                                                                      Result of Inventory

                                                                                                                                                                                     Plan
                 Identify all substances / preparations from inside EU OR which are imported from outside
           5.0   EU and have not already been registered for our use
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
                             Sent out the "Declaration of Intend" to all of our suppliers / Tracking of supplier
           5.1               responses
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           5.2               Make sure, that those substances are registered for that use by the suppliers
                                                                                                                                                                                     Progress


                                  Supplier has to confirm, that he will pre-register and has the intention to
                                  register. Supplier furthermore has to notify customer immediately if he will


  5        5.3
                                  not register the substance for the respective use



                             Make sure, that your supplier has established an Only Representative
                                                                                                                                                                        Guidelines
                                                                                                                                                                          4&6
                                                                                                                                                                                     Plan

                                                                                                                                                                                     Progress


                                  The major recommendation of the AIG is to ask the non-European suppliers
                                  to establish an Only Representative within Europe. Regrettably this first
                                  priority can not always be adopted. If for example suppliers don´t want to or
                                  are not able to establish an Only Representative in Europe further options
                                  have to be considered and could be prioritised as follows:
                                  - Priority 1: Ask supplier to establish an Only Representative and to register
                                  - Priority 2: Change your supplier or substitute the substance / preparation
                                  - Priority 3: Register by yourselves on behalf of your supplier or ask a service
                                  provider to act on behalf of you.
                                  The order especially of priority 2 & 3 is not fix but depends on the company
                                  specific policies and strategies.


                 SVHCs
                                                                                                                                                                                     Plan
           6.0   Identify:
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           6.1               SVHC in Articles
                                                                                                                                                                                     Progress

                                  Already established substance reporting systems (e.g. IMDS, MACSI) can                                         GADSL, Material
                                  be used for inventory. Prerequisite for a correct substance reporting is a                                    Reporting Systems
                                  continuously updated SVHC-list (e.g. GADSL). In case of new SVHC, an                                           (IMDS, others...)
                                  update of the reported substance information is necessary.

                                  Pre-Condition is that IMDS reporting is complete!



  6        6.2                    If necessary, do substance notification                                                                                               Guidelines
                                                                                                                                                                         8, 9, 10
                                                                                                                                                                                     Plan

                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           6.3               Imported SVHC
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           6.4               SVHC used in the EU production process                                                                            Results of Inventories
                                                                                                                                                         &                           Progress
                                                                                                                                                 Already existing                    Plan
           6.5               Compare candidate list / Annex XIV with result of identification                                                   internal processes
                                                                                                                                                                                     Progress

                             Make sure, that those substances are registered/authorized for the use by the                                                                           Plan
           6.6               suppliers (Authorisation: in case of Annex 14 inclusion)
                                                                                                                                                                                     Progress

                 Risk Management Measures
                                                                                                                                                                                     Plan
           7.0   Identify the Risk Management Measures in the SDS
                                                                                                                                                                                     Progress


  7                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       Page 110 of 120
REACH - 8 Steps compliance schedule
as of : October 1st, 2007



                                                                                                                                                                                                       2012                                                                    2013                                                                    2014                                                                    2015                                                                    2016
                                                                                                                     Main
 Steps                                                     Activities                                                           Supporter   Recommended Tools AIG Reference      Month
                                                                                                                  Responsible
                                                                                                                                                                                         Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep    Oct    Nov   Dec



  7        7.1
                 REACH AWARENESS
                            Define the RMM´s
                                                                                                                                                                              Plan

                                                                                                                                                                              Progress

                                                                                                                                                                              Plan
           7.2              Apply The RMM´s
                                                                                                                                                                              Progress

                                                                                                                                                                              Plan
           8.0   Check the conditions described in the Exposure Scenarios
                                                                                                                                                                              Progress

                                                                                                                                                                              Plan
           8.1              Verify the conditions for your use and your customers uses
                                                                                                                                                                              Progress
                                                                                                                                               Already existing   Guideline
                                                                                                                                             internal processes       5


                 In order to secure a continued supply of a substance on its own/in preparations for their



  8
                 use(s), downstream users (hereafter called “DU”), have to check whether the supplier will
                 support their use(s) and include them in the substance registration dossier to be submitted
                 to the agency. DU may only use substances on their own/in preparations which have been
                 registered for their use(s) after the registration deadline has passed. It is therefore in the
                 interest of DU to communicate early with their suppliers with view to having their use(s)
                 included in the supplier’s registration dossier.


  1              The supplier might be a downstream user, which, in turn, may decide either to carry out a
                 registration by himself or to communicate the use(s) to his own supplier. The final actor of
                 that chain is the manufacturer/importer of the substance/only representative of a non
                 Community manufacturer who may finally carry out the registration obligations.
                 (In the future, an IT-Tool will be available for communication up and down the supply
                 chain.)




                 Missing: Identify Substances which have not been / will not be authorized for our
                 use?




                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   Page 111 of 120
REACH - 8 Steps compliance schedule
as of : October 1st, 2007



                                                                                                                                                                                                                           2017                                                                    2018
                                                                                                                       Main
 Steps                                                       Activities                                                           Supporter   Recommended Tools AIG Reference      Month
                                                                                                                    Responsible
                                                                                                                                                                                           Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec


                 REACH AWARENESS

                 Request / define contact - data of REACH representative for your company and your                                                                              Plan
           1.0   suppliers                                                                                                                                                      Progress
                            Develop an internal Task Force Team chaired by the REACH representative to                                                                          Plan
           1.1              provide overall steer                                                                                                                               Progress

                                 Possible participants:
                                 R&D
                                 Purchasing
                                 Planning
                                 Overseas Sales Organisations
                                 European Plants (EH&S)
                                 Legal
                                 Quality

                                                                                                                                                                                Plan
           1.2              Identify own REACH responsible to overview the REACH deliverables
                                                                                                                                                                                Progress



                                 Under REACH, communication is required between the legal entities of each
                                 company. As one company very often has many different legal entities, the                                     Letter for REACH-


  1
                                                                                                                                                                    Annex B
                                 communication can be difficult to manage.                                                                         awareness
                                 Therefore it is recommended to appoint within one company one REACH-
                                 representative, being the central contact point and responsible to manage
                                 the company internal communication for all legal entities.
                                 It is recommended that this person is located in Europe.



                                                                                                                                                                                Plan
           1.3              Identify all own legal entities impacted by REACH
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
                            Sending out of REACH - awareness letter to all suppliers / Tracking of supplier
           1.4              responses
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
           1.5              Identify the respective REACH representative of the suppliers
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
                            Identify low, medium, high risk suppliers & define approach for handling each
           1.6              category
                                                                                                                                                                                Progress

                                 A preliminary message should be sent out as soon as possible to promote
                                 awareness of REACH in the supply chain. An example has been developed
                                 (awareness letter). It is recommended that this wording is used and that
                                 further information is not requested at this early stage.

                 SUBSTANCE INVENTORY

                                                                                                                                                                                Plan
           2.0   Identify all substances, preparations and articles falling under REACH
                                                                                                                                                                                Progress

                                                                                                                                                                                Plan
           2.1              Identify your roles under REACH
                                                                                                                                                                                Progress

                                 Please note that the level of details of the information to be collected may
                                 vary, depending on the different roles that a company may play. The matrix
                                 in Guideline 3 gives an overview of these roles and the necessary
                                 information for each.

                                                                                                                                                                                Plan
                            Recommended data for inventories, depending on the different roles
                                                                                                                                                                                Progress
                                 Downstream users must have a full understanding of what
                                 substances/preparations the company uses or imports and what are the
                                 substances in articles that the company produces or imports. Establishing an
                                 inventory will allow the company to determine:                                                                                    Guideline
                                                                                                                                                                       3
                                                                                                                                                                                Plan
                            • Which substances/preparations the company purchases from inside EU and
                              for what purpose they are used?
                                                                                                                                                                                Progress


                                 Contact the chemicals suppliers to ensure that the substance/preparation
                                 will continue to be supplied (supported by pre-registration of the substance                                      Inventory
                                 on its own or in preparations)


                                                                                                                                                                                Plan
                            • For which substances/preparations the company purchases, SDS are
                              available / not available?
                                                                                                                                                                                Progress

                                 DU must identify, apply, and, where suitable recommend, appropriate risk
                                 management measures, as indicated in the safety data sheet communicated
                                 to them, and information on risk management measures supplied to them in
                                 accordance with Article 32 REACH, or in their own chemical safety
                                 assessment (Article 37.5 REACH).
           2.2
                                                                                                                                                                                Plan
                            • Which substances/preparations the company imports and for what
                              purpose they are used?
                                                                                                                                                                                Progress
                                                                                                                                                                   Guideline
                                 Unless an “only representative of a non-community manufacturer” (that is,
                                                                                                                                                                       4
                                 an exclusive representative), who will take over the obligations as an
                                 importer, has been appointed, you will have to comply with REACH
                                 obligations as an importer.
                                 (See also Step 5.3)

                            • Which articles & materials are likely to be listed on the candidate list /                                                                        Plan
                              Annex XIV                                                                                                                            Guideline    Progress
                                                                                                                                                                       3


  2                              Outline strategies for each – is a substitution necessary?
                                 Gather data to support authorisation for your use?

                            • Which substances are intentionally released from an article that the
                              company produces?
                                                                                                                                                                                Plan

                                                                                                                                                                                Progress

                                 For articles intentionally releasing substances, you will be obliged to register
                                 the substances released under certain conditions

                                 For substances present in the article, you will have to identify whether they
                                 are of very high concern. Under certain conditions, you will have to notify the
                                 Agency for such substances

                                                                                                                                                                                Plan
                            • Which substances are intentionally released from an article that the
           2.3                company imports?
                                                                                                                                                                                Progress


                                 If no “only representative of a non-Community manufacturer” has been
                                 appointed, you will be obliged to register the substances intentionally
                                 released from the article that you import under certain conditions. You will
                                 also have to identify if the article contains substances of very high concern,
                                 and notify them to the Agency under certain conditions (See also Step 5.3)


                                                                                                                                                                                Plan
                            Define/Distinguish whether the substances are in an article (Registration acc. to
           2.4              Art. 6) or in a preparation in a container (Registration acc. to Art 7)
                                                                                                                                                                                Progress




                                                                                                                                                List of Articles   Guidelines
                                                                                                                                                                     7&8




                                                                                                                                                                                                                                                                                                                                           Page 112 of 120
REACH - 8 Steps compliance schedule
as of : October 1st, 2007



                                                                                                                                                                                                                                2017                                                                    2018
                                                                                                                        Main
 Steps                                                       Activities                                                            Supporter   Recommended Tools AIG Reference          Month
                                                                                                                     Responsible
                                                                                                                                                                                                Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec


                 REACH AWARENESS
                               Article producers/importers should pay attention under which
                                            provision of the REACH regulation the intentionally released
                                            substance/substance in preparation should be registered:                                              List of Articles      Guidelines
                                            • If the substance that requires registration is considered as a                                                              7&8
                                            substance delivered in a container, the substance has to be
                                            registered according to Article 6 REACH. Please note that the
                                            container itself may be considered as an article according to Article
                                            3.3 REACH.
                                            • If the substance to be registered is considered as a substance in
                                            an article, the substance requires registration according to Article
                                            7.1 REACH (for the definition of an article, please see Chapter 2
                                            of the Guideline). “

                                                                                                                                                                                     Plan
           2.5               Check whether article list is complete for your business
                                                                                                                                                                                     Progress


                                            The global Automotive Industry has identified that the only articles
                                            which are a part of a vehicle (have to be imported into EU within a
                                            vehicle) and intentionally release substances under normal or
                                            reasonably foreseeable conditions of use are:
                                            • Fragrance dispensers,
                                            • Fire extinguishers,
                                            • Windshield-washer fluid


  1        2.6                         Make sure, that those substances are registered for that use by the
                                       suppliers
                                                                                                                                                                                     Plan

                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           2.7                         If substances are not registered, ask supplier for registration
                                                                                                                                                                                     Progress

                 Declaration of Intent

                                                                                                                                                                                     Plan
           3.0   Inform your supplier about your use of the substances/preparations
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
                             Send out a declaration of intent including all important information to your supplier


  3        3.1               of substances and preparations / Tracking of supplier responses


                                  If conformable with the Know-How protection of the company, the
                                                                                                                                                                                     Progress



                                  downstream user should already during the pre-registration phase inform in
                                  written his suppliers of substances or preparations about his use.
                                  This will support the supplier in his later registration-process.
                                  For reasons of know-how protection it is recommendable for the
                                  downstream user not to explain the use too much in detail

                                                                                                                                                                                     Plan
           4.0   Identify all substances which will not be pre-registered by a supplier
                                                                                                                                                                                     Progress
                                                                                                                                                                        Guideline
                             Sent out the declaration of Intend to all of our suppliers / Tracking of supplier                                                              5        Plan
           4.1               responses
                                                                                                                                                                                     Progress

                             Make sure, that phase in substances are pre-registered by checking the pre-                                                                             Plan
           4.2               registration list published on January 1st, 2009
                                                                                                                                                                                     Progress



  4                               On 1 January 2009 the agency publishes the list of pre-registered
                                  substances on its website (name, numbers, registration deadline).
                                  As a user of substances check that the substances used are included on
                                  this list; if not inform the agency (art. 28.5).

                                                                                                                                                                                     Plan
                             If substance(s) are not listed on the Pre-Reg list, DU to notify ECHA for extended
           4.3               pre-registration
                                                                                                                                                                                     Progress

                                  Downstream user to notify ECHA his contact details and details of suppliers                                  Declaration of Intend
                                  ECHA to publish name of substance(s) and provide on request contact                                                    &
                                  details of DU to manufacturer / importer                                                                      Result of Inventory

                                                                                                                                                                                     Plan
                 Identify all substances / preparations from inside EU OR which are imported from outside
           5.0   EU and have not already been registered for our use
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
                             Sent out the "Declaration of Intend" to all of our suppliers / Tracking of supplier
           5.1               responses
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           5.2               Make sure, that those substances are registered for that use by the suppliers
                                                                                                                                                                                     Progress


                                  Supplier has to confirm, that he will pre-register and has the intention to
                                  register. Supplier furthermore has to notify customer immediately if he will


  5        5.3
                                  not register the substance for the respective use



                             Make sure, that your supplier has established an Only Representative
                                                                                                                                                                        Guidelines
                                                                                                                                                                          4&6
                                                                                                                                                                                     Plan

                                                                                                                                                                                     Progress


                                  The major recommendation of the AIG is to ask the non-European suppliers
                                  to establish an Only Representative within Europe. Regrettably this first
                                  priority can not always be adopted. If for example suppliers don´t want to or
                                  are not able to establish an Only Representative in Europe further options
                                  have to be considered and could be prioritised as follows:
                                  - Priority 1: Ask supplier to establish an Only Representative and to register
                                  - Priority 2: Change your supplier or substitute the substance / preparation
                                  - Priority 3: Register by yourselves on behalf of your supplier or ask a service
                                  provider to act on behalf of you.
                                  The order especially of priority 2 & 3 is not fix but depends on the company
                                  specific policies and strategies.


                 SVHCs
                                                                                                                                                                                     Plan
           6.0   Identify:
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           6.1               SVHC in Articles
                                                                                                                                                                                     Progress

                                  Already established substance reporting systems (e.g. IMDS, MACSI) can                                         GADSL, Material
                                  be used for inventory. Prerequisite for a correct substance reporting is a                                    Reporting Systems
                                  continuously updated SVHC-list (e.g. GADSL). In case of new SVHC, an                                           (IMDS, others...)
                                  update of the reported substance information is necessary.

                                  Pre-Condition is that IMDS reporting is complete!



  6        6.2                    If necessary, do substance notification                                                                                               Guidelines
                                                                                                                                                                         8, 9, 10
                                                                                                                                                                                     Plan

                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           6.3               Imported SVHC
                                                                                                                                                                                     Progress

                                                                                                                                                                                     Plan
           6.4               SVHC used in the EU production process                                                                            Results of Inventories
                                                                                                                                                         &                           Progress
                                                                                                                                                 Already existing                    Plan
           6.5               Compare candidate list / Annex XIV with result of identification                                                   internal processes
                                                                                                                                                                                     Progress

                             Make sure, that those substances are registered/authorized for the use by the                                                                           Plan
           6.6               suppliers (Authorisation: in case of Annex 14 inclusion)
                                                                                                                                                                                     Progress

                 Risk Management Measures
                                                                                                                                                                                     Plan
           7.0   Identify the Risk Management Measures in the SDS
                                                                                                                                                                                     Progress


  7                                                                                                                                                                                                                                                                                                                                             Page 113 of 120
REACH - 8 Steps compliance schedule
as of : October 1st, 2007



                                                                                                                                                                                                                         2017                                                                    2018
                                                                                                                     Main
 Steps                                                     Activities                                                           Supporter   Recommended Tools AIG Reference      Month
                                                                                                                  Responsible
                                                                                                                                                                                         Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec   Jan   Feb   Mar   Apr   May   Jun   Jul   Aug   Sep   Oct   Nov   Dec



  7        7.1
                 REACH AWARENESS
                            Define the RMM´s
                                                                                                                                                                              Plan

                                                                                                                                                                              Progress

                                                                                                                                                                              Plan
           7.2              Apply The RMM´s
                                                                                                                                                                              Progress

                                                                                                                                                                              Plan
           8.0   Check the conditions described in the Exposure Scenarios
                                                                                                                                                                              Progress

                                                                                                                                                                              Plan
           8.1              Verify the conditions for your use and your customers uses
                                                                                                                                                                              Progress
                                                                                                                                               Already existing   Guideline
                                                                                                                                             internal processes       5


                 In order to secure a continued supply of a substance on its own/in preparations for their



  8
                 use(s), downstream users (hereafter called “DU”), have to check whether the supplier will
                 support their use(s) and include them in the substance registration dossier to be submitted
                 to the agency. DU may only use substances on their own/in preparations which have been
                 registered for their use(s) after the registration deadline has passed. It is therefore in the
                 interest of DU to communicate early with their suppliers with view to having their use(s)
                 included in the supplier’s registration dossier.


  1              The supplier might be a downstream user, which, in turn, may decide either to carry out a
                 registration by himself or to communicate the use(s) to his own supplier. The final actor of
                 that chain is the manufacturer/importer of the substance/only representative of a non
                 Community manufacturer who may finally carry out the registration obligations.
                 (In the future, an IT-Tool will be available for communication up and down the supply
                 chain.)




                 Missing: Identify Substances which have not been / will not be authorized for our
                 use?




                                                                                                                                                                                                                                                                                                                                         Page 114 of 120
                                                                                                                       RE
                                                                                 Date: To be added


To CEO of all suppliers                                                                                              Reco


Subject: New European Union (EU) Regulation on Chemicals (REACH)
                                                                                                              Concerning
                                                                                                              to the REAC
As of June 2007, the European Regulation (EC) 1907/2006 concerning the Registration,
Evaluation, Authorisation and Restriction of Chemicals (REACH) entered into force.

REACH affects all industries, including the Automotive Industry (AI). As the AI is made up of                 1.   At this s
vehicle manufacturers and many tiers of the supply chain, it has several roles and obligations                     and are
under REACH. Action is required from the OEMs and suppliers, some immediately and some                             June an
over the coming 11 years and beyond.

One of the requirements of REACH is that manufacturers and importers have a duty to register,                 2.   At this s
for each legal entity, substances on their own, or in preparations that they produce or import in                  are con
quantities over 1 tonne per year (per manufacturer/importer), unless the substance is exempt
from registration. Registration requirements also apply to substance(s) intentionally released from
                                                                                                              3.   Regard
articles under certain conditions, in which case the article producer/importer is responsible for the
registration                                                                                                       take no
                                                                                                                   for the p
It is of key importance to take advantage of the pre-registration option in REACH. Pre-registration
of substances on their own, in preparations, or substances intentionally released from articles will          4.   We exp
take place between 1 June and 1 December 2008. Taking advantage of pre-registration allows for
a transitional period to the registration process and allows continued production and use of                       the REA
substances until 2010 to 2018, depending on annual tonnage. Without pre-registration,                              applicab
substances have to be registered immediately. Pre-registration is free of charge and very simple,
requiring only basic information.                                                                             5.   If you d
                                                                                                                   with our
Please consider that:
 Companies that do not comply with REACH will have no market. REACH poses a threat to
    any company doing business in the EU (and businesses with customers who do business in                    6.   We exp
    the EU).
 Business continuity can be adversely impacted by REACH and supply chains can be                             7.   Your sin
    disrupted
                                                                                                                   Please
 Companies that understand the business implications and impacts of REACH and develop
    strategic action plans will gain competitive edge over those that do not
                                                                                                                   Name, c
In order to be prepared for REACH, representatives of all the major vehicle manufacturers and
the automotive supply chain around the world developed an “Automotive Guideline on REACH”                     8.   Our sing
which can be used to get a quick overview of REACH, its requirements and the recommended                           Please
actions arising. This guideline can be found at: www.acea.be/reach
                                                                                                                   issues
This “awareness” letter with some recommendations and requests for information is considered to
be the start of the communication in the AI supply chain required by REACH. There is more to                       Name, c
come.
                                                                                                              9.   Please
Please respond as soon as you have the required information available.
                                                                                                                   Business
Regards

                                                                                                        1 The information c
                                                                                                        legally binding obli
                                                                                                        are made with rega
                                                                                                        whatsoever resultin
                                                                                                        2 See section 5.7 of
come.
                                                                               9.   Please
Please respond as soon as you have the required information available.
                                                                                    Business
Regards

                                                                         1 The information c
                                                                         legally binding obli
                                                                         are made with rega
                                                                         whatsoever resultin
                                                                         2 See section 5.7 of
                                                           COMPANY LETTER HEAD


                                 REACH: 1. Standard Communication Along the Supply Chain1
 To be added
                                                                                                                                 Jul-07

                               Recommendation and Requests from Downstream User (Customer) to
                                      Suppliers regarding Pre-registration / Registration

                        Concerning all products supplied to us which can be Substances, Preparations or Articles according
                        to the REACH terminology.
Registration,
 ce.

 made up of             1.   At this stage, we strongly recommend and expect that all substances, which require registration
d obligations                and are contained in the products you are supplying to us , will be pre-registered (between 1
 y and some                  June and 1 December 2008) by your company or by your upstream supplier.


y to register,          2.   At this stage, we also recommend and expect that all substances, which require registration and
  or import in               are contained in the products you are supplying to us, will be registered (2)
 e is exempt
eleased from
                        3.   Regarding the substances that are contained in the product and require registration – please
nsible for the
                             take note of the crucial REACH registration deadlines for those substances which are decisive
                             for the product properties.
e-registration
m articles will         4.   We expect that your business will take organisational measures to manage the implementation of
on allows for
  and use of                 the REACH regulation requirements including appointing an only representative in the EU if
 -registration,              applicable.
 very simple,
                        5.   If you do not intend to pre-register any substance that is currently in use, please get in contact
                             with our REACH contact person. (See 8 below)
 s a threat to
  business in           6.   We expect that you will appoint a single point contact for your company covering all legal entities

ains can be             7.   Your single point contact details
                             Please provide full contact details for the person in your company responsible for REACH issues
 and develop

                             Name, company, telephone & fax number mailing address and email
acturers and
 on REACH”              8.   Our single point contact details
commended                    Please find below the full contact details for the person in our company responsible for REACH
                             issues
 onsidered to
 e is more to                Name, company, telephone & fax number, mailing address and email

                        9.   Please provide your contact details and questions to:

                             Business/supply chain contacts to be inserted, if not the same as mentioned under no. 8


                  1 The information contained in this letter expresses only the intention of the requester and does not constitute a
                  legally binding obligation. Whilst the information is provided in utmost good faith, no representations or warranties
                  are made with regards to its completeness or accuracy and no liability will be accepted for damages of any nature
                  whatsoever resulting from the use of or reliance on the information
                  2 See section 5.7 of the Automotive Guideline on “Registrations of substances in articles”
      9.   Please provide your contact details and questions to:

           Business/supply chain contacts to be inserted, if not the same as mentioned under no. 8


1 The information contained in this letter expresses only the intention of the requester and does not constitute a
legally binding obligation. Whilst the information is provided in utmost good faith, no representations or warranties
are made with regards to its completeness or accuracy and no liability will be accepted for damages of any nature
whatsoever resulting from the use of or reliance on the information
2 See section 5.7 of the Automotive Guideline on “Registrations of substances in articles”
hain1

               Jul-07

 ustomer) to
on

 Articles according




equire registration
ered (between 1



ire registration and



tration – please
 which are decisive



e implementation of
ve in the EU if



 se get in contact



 ing all legal entities



e for REACH issues




nsible for REACH




.8


not constitute a
ations or warranties
ages of any nature
.8


not constitute a
ations or warranties
ages of any nature

								
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