Magna Industrial’s Statement on Compliance with REACH

The European Union Regulation EC 1907/2006, entitled “Registration, Evaluation and Authorization of Chemicals” (REACH), entered into effect on June 1, 2007. The new regulation is designed to better safeguard the environment and the health of the human population. Every Chemical Substance produced in or imported in to the EU, and meeting certain additional standards, is required to be registered with the new European Chemicals Agency (ECHA) in Helsinki, Finland. This Registration process requires extensive safety testing of Chemical Substances. The Regulation is also designed to foster better communication up and down Supply Chain, of Chemical Substance uses, safe handling and Material content.

Although REACH entered into force on 1st June 2007, the first REACH deadline which determines compliance is not until 1st December 2008. Under REACH, companies operating in the EU may face certain obligations as manufacturers, importers and/or downstream users. These obligations are staggered and become effective in stages; this means that different deadlines apply over the next ten (10) years.

1st June to 1st Dec 2008 - Currently we are in the pre registration period for existing substances manufactured or imported into the EU at 1 tonne per annum or more

1st Dec 2010 - registration complete for substances of 1000 or more tones per annum or substances of very high concern greater than 1 tonne per annum

1st June 2013 - registration complete for substances of 100 or more tones per annum

1st June 2018 - registration complete for substances of 1 or more tones per annum

The first REACH deadline and, hence, the first compliance requirement is for pre-registration of substances by 1st December 2008. The pre-registration phase only began on the 1st June 2008 and Magna Industrial Co. Limited has begun and shall complete before deadline the pre-registration process by appointing an EU “Only Representative (OR)”according to Article 8 of REACH.

• According to Article 8(1) of REACH a “non-Community manufacturer” being a natural or legal person that is manufacturing a substance, formulating a preparation or producing an article that is imported into the Community, can appoint an only representative to fulfill the registration obligations of the importers.

Hence, as a non-EU company, we are authorized to appoint a so-called “Only Representative (OR),” who would be responsible for pre-registration and all other registration requirements under REACH for imports of a particular substance or product.

Please note that we have submitted all the necessary documents to our OR and have signed an appointment letter with our “OR” for REACH compliance (Please click the “OR Appointment Letter” to see the letter). From now on, our “OR” is the only legal contact point with relevant REACH parties. For your information, our OR’s contact information is:

Ms. Helle Westphal
M.Sc. (Pharmacy)
DHI
Agern Allé 5
DK-2970 Hørsholm
Denmark

Tel: 45 4516-9200
www.reach.dhigoup.com

Please note that ECHA will not publish the pre-registered substances until early 2009. In addition, as our customer of our products, you have no possibility to check with our REACH OR or ECHA about whether the per-registration has been completed (even with the specific pre-registration numbers). If you have any inquiry on Magna Industrial’s compliance with REACH, please contact our respective distributors in your areas.

For those of you who are unfamiliar with or want to know more about your obligations under REACH may refer to http://echa.europa.eu provided by the European Chemicals Agency (ECHA). Or please click “FAQ on REACH” to read ECHA’s PDF file of “Frequently Asked Questions on REACH”.

Best Regards
Magna Industrial Co. Limited