Global Airparts & Lubricants official response to compliance with the India REACH (Chemical Management and Safety Rules)
Dear Customer
India released the fifth draft of the Chemical (Management and Safety) Rules (CMSR) on Aug. 24th, 2020. This overarching chemical law is expected to be finalized this year and will regulate Substances, Substances in Mixture, Substance in Articles, and Intermediates that are manufactured, imported, or placed in the Indian Territory.
It will require notification for all chemicals and registration for 750 priority chemicals within 18 months. All actors in supply-chain are required to comply with the CMSR. Non-Indian enterprises can appoint an Autorized Representative (AR) with a legal entity in India, which will comply with the CMSR on their behalf. Global Airparts & Lubricants is a seller of a wide range of sealants, adhesives, coatings and other specialised products used in aerospace and aviation. We recognise the role that we have under "REACH" as a distributor and importer. We also recognise that the "REACH" regulation places a heavy burden of communication within the supply chain and we fulfil our requirement to “pass” information downstream to our customers. Global Airparts & Lubricants is working with our upstream supply chain to ensure that products that are passed through to the downstream user meet the requirements of the REACH legislation and to avoid any loss of supply continuity. Global Airparts & Lubricants is working in partnership with our suppliers to maintain supply of materials; we have already seen that manufacturers are withdrawing and discontinuing products due to "REACH" requirements, often with little or no notice. This is particularly true of some niche small volume materials that have been in use within our industry for many years. The main product groups affected have been Sealants, Jointing Compounds, Coatings and Metal Treatments. In response to our obligations under the regulation and enquiries from our customers, Global Airparts & Lubricants can confirm the following:
Supplier Compliance Information
We require all suppliers to provide updated Safety Data Sheets and "REACH" Compliance statements. Not all suppliers are willing or able to do this and as such some products may need to be withdrawn from sale. We are engaging with those suppliers to try and confirm compliance and will notify affected customers if products are then withdrawn.
REACH Registration
Global Airparts & Lubricants require that all substances within products have been registered when required under "REACH". As a Seller Global Airparts & Lubricants is reliant on its suppliers to ensure that the appropriate compliance action is taken on their products. Global Airparts & Lubricants will ensure all substances in imported products comply with the registration requirements under "REACH".
SVHC Notification
Upstream suppliers to Global Airparts & Lubricants are required to advise us of any products that contain SVHC in concentrations above 0.1% (weight/weight), so that we can fulfil our obligations to inform our customers. Suppliers are expected to monitor changes to the candidate list of SVHC and inform Global Airparts & Lubricants of any affected products. We will pass this information to our customers in writing and will also add information to our website.
Safety Data Sheets
Safety Data Sheets are provided by Global Airparts & Lubricants to customers free of charge. We require our suppliers to provide us with SDSs that are updated in accordance with the REACH regulation and classified under the CLP. If a supplier makes changes to a product that affects the SDS they are required to provide Sil-Mid Limited with an updated SDS without undue delay.
If you require further assistance, clarification or technical support please contact us on e-mail services@globalairparts.in
If you would like to download a copy of Global Airparts & Lubricants "REACH" policy, please find the documentation below.