On April 7th 2010, the auditors of Kurs-Test (Russia) have renewed the GOST-R certification of CARLY refrigeration components for a period of 3 years.

This approval guarantees the quality of the manufactured products and their compliance with the Russian standards.

The European Regulation REACH (EC n°1907/2006) for Registration, Evaluation and Authorization of Chemicals, entered into effect on June 2007, generates questions and discussions.
To answer the numerous questions of its customers, CARLY decided to publish the following communiqué.

1/ Pre-Registration / Registration

The new REACH regulation aims at standardizing European Law in order to improve the protection of human health and the environment from the risks arising from the use of chemicals.

CARLY fully supports REACH objectives and works actively to ensure that its products are safely made, and present no risk for its customers and the environment.

CARLY is considered under REACH, as a downstream user, and more precisely as a « producer of articles ». It is not defined as a producer or an importer of chemicals substances on the European territory, and is therefore not required to preregister – to register the substances used in its manufacturing process.

The pre-registration and registration of the chemical substances is the producer’s or importer’s responsibility; this means our provider / manufacturer.
All our suppliers have confirmed the pre-recording of the substances liable to REACH, or their conviction that these substances are under cover of exemption.
Therefore, CARLY certify that all the sold products are in accordance with the REACH regulation. 

The pre-registration period allows you to benefit from the extended registration deadlines and to continue the raw materials supplying, until the completion of the substance registration (2010, 2013 or 2018).
A company, which omitted to preregister a substance, can not import it or produce it on the EU market, until it has submitted a full substance registration file to the European Chemicals Agency (ECHA).

According to the REACH regulation, the communication of the pre-registration’s number is not an obligation.
Only the registration’s number must be transmitted and has to be indicated on the safety data sheets, once the registration phase is completed. (In 2010, 2013 or 2018 depending on the substance).

We setup with our suppliers a follow-up to make sure that they have all required information for the registration and the use of our raw materials according to the REACH requirements, and to guarantee the continuity and the perenniality of our supplies.

2/ Substances of Very High Concern (SVHC)

As a manufacturer of articles, and according to Article 33 of the REACH Regulation, we inform you that the CARLY products contain none of the Substances of Very High Concern (SVHC), identified to date by the European Chemicals Agency (ECHA), in quantity higher than 0.1% in weight.

The substances of very high concern SVHC are substances classified as:
- Carcinogens, Mutagens and Reproductive toxicants, category 1 & 2 (CMR)
- Persistent Bioaccumulative and Toxic (PBT),
- Very Persistent and very Bioaccumulative (vPvB)
- Proven to be seriously harmful to the human body or to the environment (Endocrine Disrupters)

According to the REACH Regulation, and as other hazardous substances will be incorporated into the list of SVHC, CARLY will inform its customers of the presence of new substances in its products and the safety usage instructions.

3/ Safety Data Sheets

The main communication tool between the supplier and the customer, inside the supply chain, is the safety data sheet.
It allows to identify the presence of any hazardous chemicals agents or worrying substances (SVHC), and to assess any risk to the health and safety of the users.
Today, the provision and the content of the safety data sheet are managed by the article 31 and the annex II of the REACH regulation (sections, exposure scenarios to be included in annex, use registration...).

CARLY ensures that the uses made of its products are fully covered by the registration procedures and are provided to customers through the safety data sheets in a timely manner.

We remain at your disposal for any further information.

To download the communiqué, click on the following link: 

CARLY communiqué concerning the EU REACH Regulation