REACH regulation: Information for MAHLE customers—July 2011

Regulation (EC) No. 1907/2006 of the European Parliament and of the Council of December 18, 2006 concerning the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) came into force on June 1, 2007. REACH imposes an obligation, particularly on manufacturers and importers, to register chemicals in certain cases. Unfortunately, in many companies there is often still a degree of uncertainty as to what this registration obligation encompasses in concrete terms. In many cases, it is incorrectly assumed that REACH includes an obligation to pass on information along the supply chain, which is not actually true.

However, this leads to the companies along the supply chain feeling obliged to do this and asking each other to provide confirmation of the "REACH conformity" of the deliveries and fill in corresponding documents. Such conformity declarations are not imposed by the REACH Regulation, nor do they fulfill the prescribed registration obligations. They merely lead to considerable expense for the companies, but create neither legal compliance nor any other real benefit for those involved. We would therefore like to inform you about what information you will receive from us in accordance with the rules of the REACH Regulation.

First and foremost, as the MAHLE Group, we are a downstream user. We maintain contact with our suppliers in order to safeguard our supply of raw materials as well as the registration or pre-registration, and to take measures where necessary.

You obtain components and systems for combustion engines and peripherals as well as products for industrial filtration from the companies of the MAHLE Group. The products supplied by us are articles in accordance with the definition in Article 3, no. 3 of REACH. Our products are not articles intended to release substances contained within them (Article 7, section 1 of REACH), nor do our products contain substances posing a significant potential hazard (Article 7, section 2 of REACH). For components for the automotive industry, we already add relevant data to the IMDS database.

SVHC listed in the ECHA preliminary "candidate list" are an integral part of our MAHLE terms of purchase/buying conditions (list of banned substances).

Therefore, our products are currently not subject to any registration, notification, or information obligations by virtue of the REACH Regulation.

Of course, we will comply with the requirements of the REACH Regulation in order to guarantee the smooth running of our production at all times. We will also monitor the development of the list of substances of very high concern (SVHC) in accordance with Article 59, section 1 of REACH, and adhere to the requirements in accordance with Article 7, section 2 of REACH both now and in the future. At present, we do not envisage the function or quality of our products being restricted in any way in connection with the rules of the REACH Regulation as indicated above.

In any case, we can assure you that we are aware of the obligations arising from the REACH Regulation and will continue to comply with all legal requirements.

Please understand that we are unable to process individual questionnaires because of the large number of enquiries. This also applies to submissions on Internet portals. As a rule, the answers can be obtained from this information letter.

For any questions, please get in touch with your MAHLE sales contact person.