At HD MicroSystems L.L.C. (HD MicroSystems), Product Stewardship is an important aspect of our supply chain relationships. We maintain an unwavering commitment to the safety of our employees, vendors, customers, and the communities in which we operate. As part of that effort, HD MicroSystems has established a European team to address all of the new regulations and requirements of the European Union (EU) as they apply to our products. We would like to update you as to the status of several of these initiatives.
HD MicroSystems is making certain that our products are in compliance with the EU's REACH legislation. Under this regulation, we were obligated to register the solvent N-Methylpyrrolidone (NMP, CAS No. 872-50-4) by the end of 2010. NMP is the base solvent in many of our products.
Through our parent company DuPont, we completed that registration in September 2010 and the registration number is 01-2119472430-46-0004. With that step, HD MicroSystems has secured the availability of the affected products to Europe and assure the continuous supply to our customers. Additional registrations will be completed before the required dates in 2013 and 2018, as well as potential actions to authorise the appropriate usage and/or products, as mixtures with NMP, according to REACH .
As required by Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP), we have modified the “P- and H-phrases” on our safety data sheets (SDSs) and labels for our products VM-651, PA-400R and PA-401D. All of our remaining products are classified as preparations under the CLP regulations and those labels and SDSs will be updated as required by June 2015.
In addition, we have updated the hazard classification on the labels and SDSs for our NMP based products. The key change is the addition of the phrase “R61- May cause harm to the unborn child”. All affected SDS are available on request.
If you have any questions, please contact the European HD MicroSystems REACH Coordinator Mr. Michael Knaus (Michael.Knaus@dupont.com) or HD MicroSystems Product Stewardship Manager Ms. Patricia M. Bartlett (Patricia.M.Bartlett@dupont.com).
To understand fully the obligations that you will have under REACH, we recommend that you consult the REACH web site at http://echa.europa.eu