REACH PRE-REGISTRATION COMPLETED
14.11.2008
REACH pre-registration has been successfully completed for all relevant substances in IRMCO products.
There are no SVHCs (Substances of Very High Concern) present in IRMCO products.
At this time, there are no foreseeable problems maintaining product supply following the full implementation of REACH. IRMCO is continually assessing the availability and completeness of information to ensure compliance.
Check IRMCO News periodically for REACH status updates.
REACH related questions can be sent to REACH@irmco.com

REACH: COMMONLY ASKED QUESTIONS
Updated: June 2 2008
IRMCO is committed to continue to provide products to the EU market.
Answers to Commonly asked Questions regarding REACH:
Since IRMCO is not an EU entity subject to REACH, how are you handling REACH?
IRMCO is addressing our EU importer’s REACH obligations through an Only Representative (OR).
How does one contact IRMCO for REACH related matters?
Please email inquires to: REACH@irmco.com
Is IRMCO going to pre-register their products, such as 980-000?
Under REACH, IRMCO products are classified as preparations. Preparations are not subject to pre-registration. Preparations are made up of substances. IRMCO is addressing pre-registration for applicable substances.
Will IRMCO confirm pre-registration of all the substances in their products?
All relevant substances in IRMCO preparations will be pre-registered by November 30, 2008.
Will IRMCO forward a copy of the pre-registrations once they have been completed?
Pre-registration numbers will be provided as soon as they are available.
Are any of these substances likely to be substances of very high concern within the meaning or REACH?
We do not anticipate the identification of any substances of high concern in our products.
Does IRMCO foresee any problems in maintaining a product supply following the full implementation of REACH?
We do not expect any problems in our supply chain.
Does IRMCO have sufficient information to ensure that it and its suppliers can complete the full registration within the meaning of REACH?
IRMCO is assessing the availability and completeness of information.

IRMCO AND REACH
What is REACH?
European Union Regulation 2006/1907, Registration, Evaluation, Authorisation and Restriction of Chemicals is more commonly known as REACH. This regulation took the better part of a decade to develop and was adopted by the European Parliament in December 2006. The basic aim of the regulation is to consolidate over 40 other separate member state regulations governing the use of chemicals and improve the protection of human health and the environment overall. REACH also affects how safety information regarding substances is communicated throughout the supply chain.
When will REACH affect the European Market?
REACH officially came into force in June 2007. Concurrent with this period was the creation of the Helsinki-based European Chemicals Agency (ECHA), which is responsible for managing the registration, evaluation, authorization and restriction processes for chemical substances used throughout Europe. REACH establishes a volume-based phase-in period during which all aspects of the law will be fully realized; according to the current timetable, it will take 11 years to fully implement. The timing of events is based primarily on tonnage bands of chemicals entering the EU market as depicted below, with the highest volume chemicals generally being acted upon first.

What is IRMCO’s position regarding REACH?
IRMCO intends to fulfill its REACH obligations, including pre-registering those products which are introduced into the European Market. Like most manufacturers, IRMCO is currently preparing data to submit on applicable products once the 6 month pre-registration period begins later this year (June 1 - December 1, 2008). As required by the regulation, all pre-registration documentation will be prepared and submitted electronically to ECHA via the internet (REACH-IT/IUCLID5 database).
Further updates will be posted in the coming months.