Reach

REACH statement

Dana Lim A/S is a downstream user with regards to the substances contained in our products and therefore we do not have registration obligations ourselves.

PREREGISTRATION

Dana Lim A/S has only received positive answers from our raw material suppliers, confirming that this task have been taken care of within the time frame.

Dana Lim A/S has not experienced that our products have been affected by this first phase of the REACH process: the pre-registration.

REGISTRATION

Whether all substances also will be registered in the future, as they approaches their registration deadline is however still too soon to say. We have received some registration numbers and only very few exposure scenarios. For strategic reasons most suppliers do not wish to announce if or when they are actually going to register their substances.

At this point Dana Lim A/S are therefore not able to predict if a specific substance is already registered in 2010 or 2013, if it will not be registered till 2018 or if it will be registered at all.

We seek optimal insight at our raw material suppliers through regular contact. We use European suppliers, who in their feedback to us have stated that they are aware of their obligations under REACH and that they will comply to these.

OBTAINING INFORMATION ABOUT IDENTIFIED USES

REACH requires that all uses of a dangerous substance must be identified and risks must be controlled.

By using the “Descriptor of Use”-system Dana Lim A/S has communicated our own and our customer’s uses up the supply chain a year ahead of the registration deadline. This is to ensure that the exposure scenarios which we will receive from the substance suppliers will cover these uses.

So far we have only received very few exposure scenarios and if any deviations are detected we have communicated this to the suppliers.

On a National and European level a lot of practical work is still being done to make REACH possible to handle in real life.

So-called generic exposure scenarios are under development to make sure that each use does not need to be described again for comparable products.

An XML-format to facilitate the transmission of huge amount of data in the supply chain is under development and a phrase library is being built to ensure consistency is being built.

These projects under which the tools mentioned above are being developed have not yet finished and the tools are not yet available to the industry and IT-suppliers to incorporate in their software systems for generating safety datasheets. This is a necessary first step to be able to make harmonised and reliable eSDS.

Dana Lim A/S is participating in ETB (European Technical Board) as a representative for the Danish Adhesive and Sealant industry in FEICA (The European Adhesive and Sealant Association) and we are following the status of these very important projects closely.

THE CANDIDATE LIST

Dana Lim A/S is aware of the Candidate list with SVHC’s and our responsibility to keep us informed with the continuous update of the list. To our knowledge none of the substances listed at present are contained in our products. If in time this should be the case our general policy is to substitute substances of this high concern.

INTERNAL KNOWLEDGE AND DIALOGUE WITH SUPPLIERS

Knowledge about REACH is established in all levels in the organisation with special focus on involving the purchase and R-&-D departments. Dana Lim A/S always seeks to have more than one supplier of new and existing raw materials and to have a close dialogue with our suppliers about REACH. This way we hope to be less sensitive with regards to any potential phase out of raw materials as an effect of the new obligations under REACH.

For further general information or product specific information about REACH, please contact our REACH coordinator Dorthe Christensen by phone: +45 56 64 35 88 or e-mail: dc@danalim.dk.