HomeMy WebLinkAboutREACH - Ulbrich
Date: August 15, 2024
Subject: EU REACH SVHC Regulation (EC 1907/2006)
The uncoated strip stainless steel, nickel alloys, titanium, niobium and zirconium manufactured
at Ulbrich Specialty Strip Mill (USSM) and Ulbrich of New England (UNE) are in the form of
coils, which are classified as “finished” products in accordance with the REACH guidance
documentation. These products are classified as “articles” which do not contain “substances”
intended for release. In accordance with the REACH regulations, products classified as
“articles” are not required to register their constituent “substances”. In particular, Article 3 of
REACH defines an “article” as: “An object which during production is given a special shape,
surface or design which determines its function to a greater degree than does its chemical
composition”. Therefore, it is Ulbrich’s opinion that there are no registration requirements for
the uncoated metal under REACH.
In addition, these materials do not contain any of the June 27, 2024 EU Candidate List of 241
Substances of Very High Concern (SVHC) in amounts at or exceeding the regulated
concentrations. This list of substances triggers notification requirements for articles if certain
criteria are met, primarily the substance being present in the article at a concentration greater
than 0.1% by weight. Based on certifications from our suppliers, we believe that none of these
chemicals are present in the uncoated metal produced at our mill in concentrations equal to or
greater than 0.1% of the total product weight.
If you purchase coated/plated materials or purchase materials from a different Ulbrich site,
please contact your Ulbrich sales representative for information on those products.
Sincerely,
Skylar Nagy
Skylar Nagy
Environmental, Health and Safety Coordinator
Ulbrich Specialty Strip Mill
(203) 265-8330
snagy@ulbrich.com
ULBRICH STAINLESS STEELS & SPECIAL METALS, INC.