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Please note that this letter is for companies who have not yet submitted their REACH contact information through this website. Scroll down for further information about the REACH legislation.

 

July 8, 2008

To: CEOs of all Suppliers

From: Thomas A. McMillen, GME Vice President, Purchasing & Supply Chain

Subject: REACH Letter to Suppliers from Tom McMillen

Dear Supplier:

I am writing to request your assistance to assure compliance with the new EU REACH chemicals regulation (Reg. (EC) No1907/2006).

Please refer to WWW.gmreach.com, the GM website where we have previously provided instructions on how to take the steps necessary to be covered by a valid REACH (pre-) registration. We must receive assurance from our suppliers on or before July 15, 2008 that they will (pre-) register their deliveries of substances to us by December 1, 2008, or we may have to take action ourselves to assure REACH compliance.

We thank you for your understanding and hope that we hear from you by July 15, 2008.

 

 

January, 2008

To: CEOs of all suppliers – for delegation to Materials Management

From: Eric Alstrom, GM Europe Vice President, Global Purchasing and
Supply Chain

Subject: New European Union (EU) Regulation on Chemicals (REACH)

As of June 2007, the European Regulation (EC) 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) entered into force.

REACH affects all industries, including the Automotive Industry (AI). Because the AI is made up of vehicle manufacturers and many tiers of the supply chain, it has several roles and obligations under REACH. Immediate action is required from the OEMs and suppliers, with more to come over the next 11 years and beyond.

REACH puts the responsibility on industry to provide safety information for substances and to properly manage the risks arising from their use. Under the previous regime, the burden of proof was on governments to prove substances were unsafe and to restrict their use. REACH covers all substances on their own, in preparations and in articles, but there are exemptions for radioactive substances, non-isolated intermediates, substances during transportation and wastes. Member States may also grant exemption for substances used in the interest of defense.

One of the requirements of REACH is that manufacturers and importers have a duty to register, for each legal entity, substances on their own, or in preparations that they produce or import in quantities over one ton per year (per manufacturer/importer), unless the substance is exempt from registration. Registration requirements also apply to substance(s) intentionally released from articles under certain conditions, in which case the article producer/importer is responsible for the registration.

It is of key importance to take advantage of the pre-registration option in REACH. Taking advantage of pre-registration allows for a transitional period for the registration process and allows continued production and use of substances until 2010 to 2018, depending on annual tonnage. Without pre-registration, substances have to be registered immediately. Pre-registration is free of charge and very simple, requiring only basic information.  Pre-registration of substances on their own, in preparations, or substances intentionally released from articles will take place between 1 June and 1 December 2008.

Please consider that:

  • Companies that do not comply with REACH will have no market. REACH poses a threat to any company doing business in the EU (and businesses with customers who do business in the EU).
  • Business continuity can be adversely impacted by REACH and supply chains can be disrupted.
  • Companies that understand the business implications and impacts of REACH and develop strategic action plans will gain competitive edge over those that do not.

In order to be prepared for REACH, representatives of all the major vehicle manufacturers and the automotive supply chain around the world developed an “Automotive Guideline on REACH” which can be used to get a quick overview of REACH, its requirements and the recommended actions arising. This guideline can be found at www.acea.be/index.php/news/category/reach/.

This “awareness” letter with some recommendations and requests for information is considered to be the start of the communication in the AI supply chain required by REACH. There is more to come.

 

 

REACH: Standard Communication Along the Supply Chain1

Recommendations and Requests from Downstream User (Customer) to Suppliers Regarding Pre-registration / Registration

Concerning all products supplied to us which can be Substances, Preparations or Articles according to the REACH terminology.

1
 At this stage, we strongly recommend and expect that all substances which require registration and are contained in the products you are supplying to us, will be pre-registered (between 1 June and 1 December 2008) by your company or by your upstream supplier.
2
 At this stage, we also recommend and expect that all substances which require registration and are contained in the products you are supplying to us, will be registered.2
3
 Regarding the substances that are contained in the product and require registration – please take note of the crucial REACH registration deadlines for those substances which are decisive for the product properties.
4

We expect that you will appoint a single point of contact for your company as a whole, or a single point of contact for different business units of your company affected by REACH legislation.

General Motors will be tracking its suppliers through the use of DUNS numbers. A DUNS number is an internationally recognized common company identifier, consisting of nine digits. Every company has a Global Ultimate DUNS Number. Some companies will have additional DUNS numbers registering such business units as branches and/or subsidiaries reporting directly or indirectly to it.

If you are registering a single point of contact that represents the whole company, you will need your Global Ultimate DUNS number. If you are registering single point of contacts for different business units, you will need the branch, subsidiary or other applicable DUNS number in order to register.

General Motors asks that you submit your contact information within 10 days of receiving this letter.

5
 We expect that your business will take organisational measures to manage the implementation of the REACH regulation requirements including appointing an only representative in the EU if applicable.
6

If you do not intend to pre-register any substance that is currently in use, we expect that you will notify GM within 10 days of receiving this letter. You may do so by clicking on the link below.

Even if you do not intend to pre-register, GM expects that you will submit your contact information by clicking on the link below.
7
 Please note that submitting your contact information to General Motors does not constitute fulfilment of your REACH obligations, including, but not limited to, pre-registration or registration.
   

To provide your contact information to GM, click here.

1The information contained in this letter expresses only the intention of the requester and does not constitute a legally binding obligation. Whilst the information is provided in utmost good faith, no representations or warranties are made with regards to its completeness or accuracy and no liability will be accepted for damages of any nature whatsoever resulting from the use of or reliance on the information
2See section 5.7 of the Automotive Guideline on “Registrations of substances in articles”