HomeMy WebLinkAboutREACH - Cleveland Cliffs CLIFFS
CLEVELAND-CLIFFS INC.
Cliffs Steel Inc.
200 Public Square,Suite 3300.Cleveland.OH 44114
P 216 694 5700 clevelandcliffs.com
July 10, 2023
Subject: REACH Legislation EC 1907/2006
REACH Annex XIV
REACH Annex XVII
REACH Candidate List
To Whom It May Concern:
The European Chemicals Agency("ECHA") prioritizes substances of very high concern ("SVHC")from the
Candidate List ("REACH Candidate List") to determine which substances should be included in the
Authorization List Annex XIV ("REACH Authorization List"). These substances cannot be placed on the
market or used after a given date unless an authorization is granted for their specific use. The Authorization
List ("REACH Annex XIV") is regularly updated with substances from the Candidate List (which itself is
regularly updated). Restrictions on substances, mixtures or articles are set out in the Restricted Substance
List Annex XVII ("REACH Restricted Substance List") and the REACH Restricted Substance List refers to
the conditions attached to the substance restrictions.
Once a substance is included on the Candidate List, it creates certain legal obligations for the European
Union ("EU") importers, producers, and suppliers of an article that contains such a substance. REACH
defines an "article" as an object which during production is given a special shape, surface or design that
determines its function to a greater degree than its chemical composition. The steel products supplied to
your company by Cliffs Steel Inc. ("Cliffs") are considered articles consistent with REACH definitions.
EU/EEA manufacturers or importers of an article which contain a SVHC (i.e., is on the Candidate List or
the Authorization List):
• in quantities of 1 tonne or more per year(tonnage of the SVHC not the article); and
• the concentration of the SVHC in the relevant part of the article is above 0.1%weight by weight
(w/w)
are required to make a notification to ECHA unless the substance has already been registered for that
specific use.
As of the date of this letter the steel products we deliver contain no SVHC above the current REACH
notification thresholds. We monitor the Candidate List of SVHC and will inform our customers in the event
any changes to the requirements include a substance contained in our steel products.
The information in this letter is provided by Cliffs Steel Inc.for itself and, if applicable,for its subsidiaries,Cleveland-Cliffs Steel Corporation
and Cleveland-Cliffs Steel LLC,for the general information of customers and does not imply any warranty.The interpretation or use of this
information is the sole responsibility of the user. This information is provided to you on the following conditions: (1) Cliffs makes no
representations or warranties as to any tests used in preparing this letter or correctness of its contents;(2)Cliffs shall not be liable to you or
any other person for the performance,merchantability,suitability or fitness for any purpose of any material or item tested or investigated in the
preparation of this letter, whether such liability is asserted on the basis of express or implied representations, warranties or conditions, in
contract or tort,by statute or common law,or on any other basis;and, (3)you agree to hold Cliffs harmless against any liability that may be
imposed on it in connection with this letter,the manufacture of any item in reliance on it,the use of any item so manufactured or the breach of
any of these conditions.
Under REACH guidelines, a North American company that exports product to the EU is not obligated by
REACH to register or make notifications itself as REACH only obligates EU based companies or nominated
EU representatives of the non-EU exporter. REACH obligations for non-EU exporters must therefore be
fulfilled by the EU importers or by an EU appointed representative. Consequently, the registration or
notification with ECHA of a substance covered by REACH is not the responsibility of Cliffs.
Should you have any questions or require further information, please contact the undersigned at
evelyn.hoffman@clevelandcliffs.com.
Ever H ffma
Dire tor, Cent al Quality