This information is intended to answer questions that our consumers may typically have about REACH and Prime Cures products.
GENERAL INFORMATION ON REACH
Regulation (EC) 1907/2006 on the Registration, Evaluation and Authorisation of Chemicals (REACH) is a European Union Regulation and came into force on June 1, 2007. It defines various measures to limit the use of certain hazardous chemicals and regulates the consumer exposure to such chemicals. Under REACH, companies operating in the EU face various legal obligations, one of which is to respond to questions from end consumers on whether certain listed substances are present in Swarovski products and if so, to provide sufficient information to allow a safe use. Swarovski is well aware of the several steps that need to be undertaken to comply with REACH and acts accordingly.
NOTIFICATION FOR SUBSTANCES OF VERY HIGH CONCERN IN ARTICLES
If an article contains so called substances of very high concern (SVHC) in a concentration above 0,1% weight by weight, the consumer may request information about this fact, the name of the specific SVHC as well information about the safe use of the article.
With exception to the articles mentioned under “NOTIFICATION” below, IVARAH HAS NOT BEEN MADE AWARE BY ANY OF OUR SUPPLIERS THAT ANY COMPONENT OF A IVARAH ARTICLE CONTAINS ANY SVHC IN A CONCENTRATION ABOVE 0,1% WEIGHT BY WEIGHT. ALL IVARAH PRODUCTS UNDERGO A REASONABLE AND STATISTICAL TESTING PROGRAM VERIFYING THAT THEY ARE FREE FROM SVHCs IN A CONCENTRATION ABOVE 0,1% WEIGHT BY WEIGHT.”
Ivarah re-evaluates this statement without delay with every amendment of the SVHC list and with any new information concerning SVHCs.
Ivarah is committed to actively restrict the use of harmful chemical substances in all its products. Ivarah wants to maintain strict control over the substances used and therefore takes the lead in the industry by establishing our own stringent global standards for the management of chemical substances. Our program, called PÚRÉ, and our standards are obligatory for all our global manufacturing facilities and all our suppliers manufacturing Swarovski products throughout the world. REACH is an integral part of PÚRÉ program and fully on our radar.
Should your concern not be adequately addressed, please do not hesitate to contact us via pure@ivarah.com.
NOTIFICATION
According to Article 33 of 1907/2006/EC REACH we would like to inform you that certain parts of the watch movement used for Swarovski watches contain Lead (Pb; CAS No. 7439-92-1) above the SVHC notification limit of 0,1 % weight by weight. When used as intended, the products do not pose a health risk.
All Ivarah watch items comply with Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS). Ivarah watch movements fall under the exemption of Annex III of the Directive, entry 6(c).
Regulation (EC) 1907/2006 on the Registration, Evaluation and Authorization of Chemicals (REACH) came into force on June 1, 2007. Under REACH, companies operating in the European Union face various legal obligations, one of which is to provide sufficient information about certain hazardous chemicals contained in the products they supply. Ivarah is well aware of the several steps that need to be undertaken to comply with REACH and will act accordingly.
The implementation work was already started early in 2006 in order to ensure that Swarovski is well prepared for REACH. Our team of experts is monitoring REACH closely and implements all necessary measures to ensure a smooth transition into the REACH era, thus avoiding any unnecessary disruption in the marketing and supply of Ivarah articles.
A substance of very high concern (SVHC) is a chemical substance (or part of a group of chemical substances) for which it has been proposed that the use within the European Union be subject to authorization under the REACH Regulation. Indeed, listing of a substance as an SVHC by the European Chemicals Agency (ECHA) is the first step in the procedure for restriction of use of a chemical. The list of SVHCs is regularly updated and the most recent list of SVHC substances under EU law is published on the web page of the ECHA and can be reviewed here
REACH regulates that if an article contains so called substances of very high concern (SVHC) above 0,1% weight by weight concentration, the supplier of the article in question shall provide the recipient with sufficient information to allow safe use of it, including, as a minimum, the name of the SVHC contained in the article. Such information is free of charge. With regard to Swarovski products, please see our statement above.
Ivarah has registered, where necessary, all substances manufactured in or imported into the European Union. For chemicals and articles sourced in the EU, Ivarah is a downstream user. As such we have sought communication with our suppliers to ensure that key raw materials will be supported and that our manufacturing processes will not be affected. We can, however, not guarantee that our suppliers register all their products and take our uses into account. Should problems in our supply chain arise, Ivarah will work hard with its suppliers to solve them, as this is in the mutual interest of all parties involved.
A downstream user means any natural or legal person established within the Community, other than the manufacturer or the importer, who uses a substance, either on its own or in a preparation, in the course of his industrial or professional activities. A distributor or a consumer is not a downstream user.
The risk assessment on the use of a chemical in question plays a central role in the REACH concept and will require the exchange of information between supplier and downstream user. Ivarah generally has a very good understanding of the typical applications of its products by its downstream users, if these articles are used according to the intended application. On demand Ivarah will timely request all information needed from its downstream users, in case this will be necessary. Generally, no immediate action by you is required at the moment.
In case you use our articles in a way that is contrary to that for which they have specifically been developed, or in a way that you suspect we have no knowledge of, you may wish to let us know through communication up the supply chain.
We would like to inform you that the identification of substances as substances of very high concern (SVHC) is a multi-step process:
A EU member state prepares a document detailing the reasons why it believes that a dangerous substance is of “very high concern”. This work is usually not done in public but only on initiative of the competent authority of a member state.
The ECHA then collects these documents and publishes them on its website as a “consultation” (see here). This happens multiple times a year. At the end of the consultation a consensus is reached and this will be to either include a particular substance on the SVHC list, or not to include it.
The number of SVHC steadily increases and is published by ECHA. The most recent list of SVHC substances under EU law is published on the web page of the ECHA and can be reviewed here
