REACH at S&D

Group companies source and supply performance chemicals, pharmaceutical intermediates/APIs, cosmetic and food ingredients and natural aromatic oils. These companies are committed to REACH-compliance and this is being achieved at S&D through a dedicated Steering Team co-ordinated by our experienced in-house REACH Manager responsible across the Group for all relevant issues. Under his leadership, a matrix organisation has been formed to ensure the timely compliance of Group commitments.

S&D REACH strategy: Our strategy is to ensure continuity of supply for our customers and facilitate the information flow for our suppliers by assuming different REACH-designated roles:     • Distributor: Most of our EU-based suppliers have confirmed their commitment to register their own substances. S&D therefore is geared to deliver on its Distributor obligations     • Importers: In selected products S&D will pre-register substances as Importers and pursue the registration obligations     • Only Representative (OR): We have agreed with some of our non-EU manufacturers to work as their OR to deliver the REACH obligations on their behalf. Pre-registration of substances thus will be completed during the required timeline of Jun-Nov 2008.

REACH actions being undertaken at S&D:     • Preparation of inventory of substances based upon classification, volume bands, desired legal entities for registration, possible exemptions     • Compliance under Article 31 (modified safety data sheets - SDS) ensuring effective chemical safety analysis/hazard communication in the supply chain. S&D commits to supply appropriate information (Article 32) where a substance does not need an SDS     • Compliance of marketing and use restrictions (Annex XVII under provisions of Article 67)     • Supporting harmonisation of classification/labelling for substances with CMR PBT and respiratory sensitizers (Annex XV and Article 115)     • Promoting supply chain communications on aspects of substance use and exposure scenarios.

As REACH matters progress beyond pre-registration/registration phases, our project status will be periodically communicated.
S&D will comply in full with its obligations under Regulation (EC) No 1907/2006 (“REACH”) and all other associated guidance documents.

For any queries regarding REACH in our product range contact: reach@sdcldn.com