What is this request about?
Substances on the REACH Restrictions List (Annex XVII) are subject to restriction under REACH, which involves limits or bans on the manufacture, sale, or use of the substance. A restriction applies to the restricted substance on its own, or used in a mixture or an article.
Restrictions under REACH are not all the same. Restriction may involve a complete ban on the substance, or may only include specific limitations on the substance's use. Some restricted substances may still be used under an applicable exemption, or may be used for applications not prohibited by the restriction. For example, if a substance is on the Restricted Substances List with a limitation prohibiting it from being mixed with water, the substance can still be used if it will not come into contact with water.
How do I start?
In order to be able to complete this request, you will require information on the chemicals contained in your parts/products. If you do not manufacture the parts/products yourself, the information can be obtained by requesting it from your suppliers.
A REACH Restrictions list (Annex XVII) declaration should be on a company letterhead with a current date and a signature of an authorised person. It should also include a clear position statement whether the parts/products you supply to your client contain or don’t contain any substances on this Annex XVII list. The latest list update from March 2020 that now contains 70 substances also needs to be mentioned.
Why is my customer asking me for this information?
The objective of the REACH Restrictions list is to collect information about whether Annex XVII substances are present in the parts/products that are being supplied to your client. This will allow your client to identify any situations where restricted substances are present and a restricted substance declaration is required, in order for the parts/products to be placed on the EU market.
In summary, your customer needs this information from you in order to import their parts/products into the EU and to place them on the EU market.