REACH Statement
Registration of Substances
After careful review of the legislation and specifically the definition of an “article” as defined in EC Regulation 1907/2006, Title II, Chapter 1, Article 7.1(a)(b), it is our current view Multi-Tech Systems, Inc. products would be considered as “articles”. In light of the definition in § 7.1(b) which requires registration of an article only if it contains a regulated substance that “is intended to be released under normal or reasonably foreseeable conditions of use,” Our analysis is that Multi-Tech Systems, Inc. products constitute nonregisterable articles for their intended and anticipated use.
Substances of Very High Concern (SVHC)
Per the candidate list of Substances of Very High Concern (SVHC) published October 28, 2008 we have reviewed these substances and certify the Multi-Tech Systems, Inc. products are compliant per the EU “REACH” requirements of less than 0.1% (w/w) for each substance. If new SVHC candidates are published by the European Chemicals Agency, and relevant substances have been confirmed, that exceeds greater than 0.1% (w/w), Multi- Tech Systems, Inc. will provide updated compliance status.
Multi-Tech Systems, Inc. also declares it has been duly diligent in ensuring that the products supplied are compliant through a formalized process which includes collection and validation of materials declarations and selective materials analysis where appropriate. This data is controlled as part of a formal quality system and will be made available upon request.
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