Project is N America (outside USA). Manufacturer is Europe HQ with global operations; uses European standards for global manufacturing. Materials will be produced in USA/ shipped to project outside of USA. Would they be able to qualify for International Alternative Compliance Path: REACH Optimization? Guidance requested on how manufacturer document?
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Paula Melton
Editorial DirectorBuildingGreen, Inc.
LEEDuser Moderator
183 thumbs up
January 26, 2018 - 9:46 am
REACH optimization should be available; the important thing is that the project is outside the U.S. A European manufacturer should be familiar with how to document REACH compliance.
Sandra Moran
AdvocateEcoAdvisor Group LLC
January 26, 2018 - 12:16 pm
Thanks for your reply Paula. Confirming: project is outside USA; but materials will be manufactured in USA and shipped to project outside USA. Since this is first project attempting this credit the manufacturer has concerns about documentation for LEED v4. Do they submit dossier for all substances in finished good or other form/documentation?
Paula Melton
Editorial DirectorBuildingGreen, Inc.
LEEDuser Moderator
183 thumbs up
January 26, 2018 - 12:34 pm
They do not have to disclose everything in the product; they must give you documentation of what it does NOT contain. The reference guide calls for:
clear documentation from the supplier that they do not contain any substances on the “Authorization List” (chemicals that can only be used with special authorization) nor on the “Candidate List” (chemicals being considered for the Authorization List)
Sandra Moran
AdvocateEcoAdvisor Group LLC
January 26, 2018 - 12:53 pm
That said, we'd assume that a self-declaration REACH Compliance Certificate or REACH Declaration Letter will meet the needs. Please if you advise if you agree or have identified other language that requires third-party certification.
Paula Melton
Editorial DirectorBuildingGreen, Inc.
LEEDuser Moderator
183 thumbs up
January 26, 2018 - 1:11 pm
The reference guide does not say anything about third-party review. Self-declaration should be sufficient.
Sandra Moran
AdvocateEcoAdvisor Group LLC
January 26, 2018 - 2:08 pm
Thanks again Paula! Your insight is greatly appreciated.
Josef Andersen
Sustainability specialist, LEED APVolvo cars
September 19, 2024 - 5:33 am
Dear all!
We recieved self-declaration doduments from several of our suppliers but I am not sure wether they are valid or not to meet the credit? How do you know what should be stated in the document in order to make sure they fulfilll the requriements?
This is what is written in one declaration that we recieved from one supplier in this case Paroc:
"REACH coverage:
This statement confirms that PAROC has fulfilled the REACH obligations for all legal entities (production units) below;
Paroc Oy Ab, Finland
Paroc AB, Sweden
Paroc Polska Sp. z.o.o, Poland
UAB Paroc, Lithuania
Substance registered:
Substance Identification: EC number 926-099-9
Reference Substance Name: ”Man-made vitreous (silicate) fibres with random orientation with alkaline and alkali earth oxides (Na2O+K2O+CaO+MgO+BaO) content greater than 18% by weight and fulfilling one of the Nota Q conditions.”
Public Name: MMVT Note Q Fibres
Classification: Not Classified
Man-made vitreous (silicate) fibres with an index number of 650-016-00-2 fulfilling one of the Note Q conditions in the CLP Regulation (EC) No 1272/2008, as amended in Regulation (EC) No 790/2009 and thus exempted from classification.
The registration covers the fibres as substance in all PAROC products (loose wool, slabs, mats, rolls, bats etc).
Products as such are not covered by REACH and PAROC (and neither customers) do not have obligations with regards to those.
Following the registration, PAROC states that Paroc Stone Wool products do not contain (nor are they added in production) the substances mentioned in the “Candidate List of substances of very high concern (SVHC) for Authorisation” of REACH (updated 2024-01-23), REACH Restricted Substance List 2020 (REACH Annex XVII) or REACH Authorisation List (REACH Annex XIV) in a concentration above 0.1% weight by weight."
BR,
Josef