Reach Statement

Introduction of the REACH (Registration, Evaluation and Authorisation of Chemicals) regulation for EU companies came into force on June 1st 2007. It relates to all manufacturers, importers and downstream users of chemicals and registration of all quantities over 1 tonne or more per year.

Logitech position and relevance to REACH.
The classifications describe:

Substances – Are chemical substances. For example: Logitech Chemlox polishing fluids and cleaning fluids.

Preparations – Consist of more than one ‘chemical’ substance within the preparation. i.e. Logitech SF1 polishing fluid.

Articles – An article is defined as an object whose shape, surface or design has a greater effect than its chemical composition. REACH distinguishes between articles with an intended release of substances and with no intended release of substances. REACH only applies to articles with an intended release of substances. So for example: Logitech powdered lapping and polishing abrasives; saw blades; lapping and polishing plates and accessories are not covered by REACH as they have no intended release of substances.

The timeline for compliance is:

Pre-registration – between 1st June 2008 and 1st December 2008.

> 1 tonne per year – between 31st May 2013 and 31st May 2018

Larger (>100 or >1000 tonnes) or classified as more toxic substances must comply between 1st December 2008 and 31st May 2010.

Logitech Compliance Program:

a) Individual chemical substances: Logitech is recognised as a downstream user. All chemical substances are imported from EU suppliers and as such the obligation lies with the manufacturer. Logitech therefore is not obliged to register these substances.

b) Quantities in excess of 1 tonne manufactured or imported from outside the EU: Where Logitech does choose to import materials manufactured outside the EU, Logitech will ensure the materials have ‘only representative’ registration in place under REACH. Logitech thereby always acts as a ‘downstream user’ and is not obliged to independently register substances, preparations or articles.

c) Pre and subsequent registration of substances, preparations or articles manufactured or imported from outside the EU of quantities of 1 tonne or more per year. Logitech will continue to monitor the levels and origin of all substances, preparations and articles manufactured or imported from outside the EU and if such levels of each or any exceed the limits recommended by REACH will register them as regulations dictate.