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Delphi Reach Statement

Date: 21 September 2017

Subject: REACH Reporting - Certification / Notification

To: Power and Signal Group

This letter is in response to your request for information concerning products supplied to you by Delphi Automotive and its affiliates (collectively, “Delphi”). Products are defined herein as substances, preparations, or articles according to the European Union Regulation EC 1907/2006.

Delphi is committed to taking the necessary steps to ensure compliance with European Chemicals Regulations REACH (Regulation European Community 1907/2006). Delphi understands its REACH obligations and has formed a global team for implementing its internal business process. These measures are designed to ensure applicable REACH compliance for substances, preparations, and articles used or manufactured in the EU and for those imported into the EU by Delphi or its authorized representatives. We have also implemented a continuous process for gathering information concerning our wide array of products as necessary to assist our suppliers and customers in complying with their registration and notification obligations under the EU REACH regulation. In general, Delphi is a supplier of articles, and not a supplier of substances and preparations.

Just as you rely upon Delphi to provide information on the materials, parts, and subcomponents we supply you, Delphi relies upon its suppliers in gathering this information. The accuracy and completeness of our information depends upon the reporting of our suppliers, and the many cascading tiers of part and material manufacturers that ultimately feed the vehicle industry at large. Delphi is obligating its suppliers to provide complete and accurate data, and Delphi has gathered and treated the information with due care and reasonable diligence. To the best of our knowledge, and per the Automotive Industry Guideline, www.acea.be/reach, substances and preparations used in the articles supplied to our customers do not intentionally release and are integral to the functioning of the part, and therefore are not subject to REACH registration. We have also determined that, at this time, Delphi does not have substances in articles falling under the conditions of Article 7(2) requiring notification. In addition, Delphi will rely on the substances of concern data reporting process via the International Materials Data System (IMDS) and the Global Automotive Declarable Substances List (GADSL www.gadsl.org) to identify and notify you of the substances of very high concern (SVHC) contained in the articles supplied to you. There is wide automotive industry acceptance of the use of already existing Material Management Systems (e.g. IMDS, CAMDS, MACSI…) to fulfil Art. 33 obligations. There are also processes in place updating the GADSL with ECHA dossier potential SVHC substances as they apply to the automotive industry.

Delphi will notify you of the SVHC content of our products utilizing IMDS submissions, or equivalent, with updates and resubmissions as needed. Directed buy parts will be tracked and if your assistance is required, we’ll contact you. Service parts that are no longer in current production are a lower priority for tracking and replacement. We are working with the European REACH Task Force (REACH TF) and ACEA which are working with the EU Commission to obtain needed exemptions for replacement/spare parts for durable consumer goods, such as vehicles, airplanes, etc. Delphi is closely monitoring the addition of substances to the REACH Candidate List and Annex XIV. Analysis of our products and suppliers data is on-going to assure that we continue to be in compliance with the European Chemicals Regulations REACH. Delphi’s strategy will be to pursue the replacement of substances not receiving authorization by ECHA or by customer specification in a timely manner prior to the “sunset dates.” For applications/uses that do receive authorization, we will work with suppliers, and will be in contact with all customers prior to the “sunset dates”. Prohibited substances will be investigated for elimination if they occur above the threshold limit and/or are used in a prohibited application.

Please don’t hesitate to contact me if you have any questions concerning this communication.

Sincerely,

Hector Gutierrez

Director, Global Operations on behalf of Delphi Automotive and its affiliates

 

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