Annex II: Letter template - the European Environmental Bureau

Transcription

Annex II: Letter template - the European Environmental Bureau
Elise Bonneau
Rue de la Filature 18
B-1060 Saint Gilles
elisebonneauhotmail.com
Coleman Benelux B.V.
Minervum 7168
NL-4817 ZN Breda
THE NETHERLANDS
March 2nd, 2010
Re: High Concern Chemicals
Dear Sir/Madam,
As required by the European regulation on chemicals, REACH EC 1907/2006, I
would like you to inform me about the presence of any chemical substance from
the “Candidate List of substances of very high concern” in the products you sell.
If any of these dangerous chemicals are present, the law specifies that you name
them, and give me sufficient information to allow safe use of the product, within
45 days. For more information on your obligations under REACH, please find
your National Help Desk here:
http://echa.europa.eu/help/nationalhelp_contact_en.asp
I would like to know about the presence of any other harmful chemical in this
product and its packaging. More specifically I would like to have information
whether products or their packaging contain any of the 356 chemicals identified
by Environmental groups as hazardous for human health (causing cancer, or sex
altering chemicals) and the environment. The substances I refer to here are
included in the so-called SIN list 1.1 which is to be found at
http://www.chemsec.org/list/about-sin.
In this context I would like to know whether you have a customer policy in place
seeking to offer products which don’t contain hazardous substances included in
the SIN list 1.1or if you have a time plan to substitution.
Sincerely,
Elise Bonneau
May 26th, 2010
European Environmental Bureau
Boulevard de Waterloo 34
B-1000 Brussels
Re: Substances of Very High Concern
C&A Belgique
Avenue Jean Monnet
B-1804 Vilvorde
Dear Sir/Madam,
As required by the European regulation on chemicals, REACH EC 1907/2006, I would like you to
inform me about the presence of any chemical substance from the “Candidate List of substances of
very high concern” in the following product and its packaging if applicable: T-Shirt, 386 A1854714
0098 92, 12€
Reminder of
supply chain’s
requirements
under
REACH
art.33
According to Article 33 of REACH, any supplier of an article containing a substance meeting the
criteria in Article 57 and identified on the candidate list, shall provide the consumer with sufficient
information, free of charge, within 45 days of receipt of the request. As a minimum the following
information should be provided:
- Name of the substance
- Sufficient information ensuring safe use of the article for the consumer
Please note that this letter constitutes a personal consumer request according to art.33 of REACH and
is not submitted on behalf of an NGO.
Links to
Candidate
List and
ECHA
guidance
For more details on the minimum information to be provided please check at
http://echa.europa.eu/chem_data/authorisation_process/candidate_list_obligations_en.asp and
http://guidance.echa.europa.eu/docs/draft_documents/Draft%20Guidance%20on%20requirements%2
0for%20SiA_CARACAL.pdf
NGOs have identified a list of 356 harmful chemicals meeting the official REACH criteria of SVHC.
This list of substances (SIN list 1.1) is to be found at http://www.chemsec.org/list/about-sin.
NGOs strongly encourage the substitution of these “worst of the worst” chemicals by safer alternatives
(substitution principle). Therefore we are interested to know whether:
1. You have a chemicals policy in place, in particular a pro-active substitution policy;
2. (if applicable) a concrete time plan for implementing phasing out and substitution;
3. You have heard about the SIN 1.1 list and you actively promote it through your supply chain;
4. You have reasons or justifications on continued use of these substances, and in what articles;
5. (if available) detailed information of volumes of SVHC placed on the market within your
products/packaging
Please also note that we reserve the right to evaluate and communicate the response received.
Sincerely,
P.S.: Please consider this letter as a personal request.