Crisa statement regarding REACH regulation compliance

Regarding the European REACH regulation which is applicable to all industry across the entire European Economic Area, COMPUTADORES REDES e INGENIERIA SAU (Crisa) declares:

What is REACH?

REACH is the Registration, Evaluation, Authorisation (and restriction) of Chemicals. The first of a set of chemicals related regulations entered into force on 1st June, 2007 to streamline and improve the former legislative framework on chemicals (substances in REACH terminology) within the European Economic Area (EEA). REACH places much greater responsibility on industry to manage the risks that substances may pose to health and the environment.

REACH has two main goals:

1. To improve the protection of human health and the environment by gradually eliminating hazardous substances from use.

2. Increase the communication through the entire supply with respect to hazardous substances and the products (preparations and articles) that contain them.

So What Does REACH Actually Require?

REACH is extremely complex legislation that has many requirements for industry. The main ones are as follows.

1.   Registration: Requires every manufacturer (or importer) of almost all substances used in industry to register that substance with ECHA by one of three pre-determined deadlines. If the manufacturer has not registered the substance by the appropriate deadline, then that manufacturer may no longer place the substance on the market in the EEA.

2.   Communication of uses: Requires users of substances, or preparations that contain them, to submit their specific uses to the manufacturer using a five part use-code. If the manufacturer does not accept this use by including it on the Safety Data Sheet, then the user may no longer use the substance for that use.

3.   Communication of Candidate List substances: Identifies certain substances as Substances of Very High Concern (SVHC) which, when added to the Candidate List, require additional reporting:

a. Inform customers and custodians of articles distributed outside of the legal entity if the article contains more than a threshold amount of any such substance.

b. Inform ECHA if the legal entity uses more than one tonne of the substances in its products each year.

4.   Authorisation: Any substance on the Candidate List included also in the Annex XIV requires ECHA authorisation in order to be used after a predetermined sunset date.

5.   Reclassifies many substances as hazardous, when previously they were not.

6.   Significantly increases the amount of information that must be included on a Safety Data Sheet and imposes a new communication for substances in articles.

7.   Imposes new labelling and packaging requirements for hazardous substances and preparations.

 

Which Ones Affect Crisa?

 

Registration:

Crisa does not manufacture or import substances in significant quantities, so the process of registration does not apply to Crisa.

Crisa does, however, have to ensure that the substances used, including those in preparations, have been duly registered by the manufacturer.

Authorisation:

It is Crisa policy not to use a substance that requires ECHA authorisation as far as possible. Crisa will start replacement activities as soon as a substance gets added to the Candidate List.

Implementation:

Crisa has worked coordinated with Astrium to ensure that the legislation is correctly interpreted for the Crisa business case and that we do no more than is necessary to comply with that interpretation.

Therefore with this letter we can declare that Crisa is complying with the legislation and Crisa is working to maintain and control the compliance of that Reach regulation.


Computadoras, Redes e Ingeniería, S.A.U.
Company registered at the Madrid Trade Register, 1st Inscription, Sheet 67.213, Folio 78, Book 807, General 765, Section 3. Tax ID Code (CIF) A-78066735

Crisa, an Airbus Defence and Space company