Dow Reply - D4 D5 D6

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De : reach.

support - dow
Envoyé : mercredi 5 juin 2024 09:02
À : Adeline Courbet - UnivarSolutions
Objet : FW: UNIVAR SOLUTIONS_Adeline Courbet-XM PMX-200 SIL FLUID 1000CS-REACH Annex xVII-
70-00201188

Dear Adeline,

Thank you for your inquiry.

Please find below our customer information on REACH Annex XVII, entry70 (D4/D5/D6):

• On 16th May 2024, the European Union published the REACH “leave-on-restriction”
of D4, D5, D6 in the official journal.
• This restriction focuses on personal care, consumer, and professional applications
• Derogations allow the continued use of D4, D5, and D6 in specific industrial
applications and for silicone polymer production. (see details below)
• REACH “leave-on-restriction” of D4, D5, D6 restricts the placing on the market of D4,
D5 and D6 in personal care, consumer, and professional applications as substances,
as constituents of other substances, or in mixtures in a concentration equal to or
greater than 0.1 % weight by weight of each substance. The limit has been set to 1%
wt. in adhesives and sealants.
• The timeline for compliance is as follows:
▪ 2 years: for all uses, including D6 in wash off cosmetic applications.
o Longer compliance windows for the following uses:
▪ 3 years: leave-on cosmetic products and medical devices
▪ 7 years: medicinal products for human health and veterinary medicinal
products

• Derogations allow the continued use of D4, D5, and D6 in specific industrial
applications and for silicone polymer production:
o Industrial use as a monomer in the production of silicone polymer
o Industrial use as an intermediate in the production of other organosilicon
substances
o Industrial use as a monomer in polymerisation
o Industrial use in formulation and/or (re)packing of mixtures
o Industrial production of articles
o Industrial use in non-metal surface treatment
o Industrial use as laboratory reagent in Research & Development activities
• You can be re-assured that Dow continues to innovate and invest in silicone
chemistry to bring safe, performance-enhancing, and sustainable materials that bring
essential benefits to reduce impacts of modern society on health and the
environment.
• Dow products containing various levels of D4, D5 and D6 are available for use. Dow
will continue to support our customers with products that meet their needs while
complying with global regulatory requirements.

For further information on reportable ingredients please consult our EU MSDS, in section 15 you may
find information on REACH Annex XVII. Most of our recent MSDS can be extracted from our website
at the following link https://www.dow.com/en-us/support/sds-finder.html . In case you cannot
find it please use the following link to request support: Literature Request | Dow Inc.
If you have additional questions, please don’t hesitate to contact Dow Silicones and we will do our
best to assist you.

Have a nice day

*Note: This survey is being conducted by Dow's Customer Experience Team, a part of Dow's Global Commercial
Function. Your input will be confidential. Your response Is not anonymous to facilitate follow-up with you if needed. In addition,
this survey is processed on a global system that is administered in the U.S. Data will be analyzed on an individual and
aggregate basis globally. Personally identifiable data will be stored for no longer than 5 years.

Best regards / Mit freundlichen Grüßen / Sincères salutations

i.A./p.o. Monika Désor , REACH Specialist

Dow Silicones Deutschland GmbH, Rheingaustr. 34, D-65201 Wiesbaden

DOWSIL™ SILICONES BY DOW


Geschäftsführer: Julia S. Schlenz , Jean-Philippe Meyer , Jana Kramer
Amtsgericht Wiesbaden HRB 2956
Steuernummer: 40 231 6094 7,Umsatzsteuer-ID: DE113839029

Dow Silicones Deutschland GmbH


A wholly owned subsidiary of The Dow Chemical Company
www.dow.com

Disclaimer: (Please Read Carefully):


The content of this document is for general information only and represents The Dow Chemical
Company and its affiliated companies’ interpretation of, and comments on, the REACH
regulation (and any other legislation referred to herein). No guarantees, undertakings or
warranties concerning the accuracy, completeness or up-to-date nature of the information
contained herein are provided. The Dow Chemical Company and its affiliated companies)
does not invite reliance upon nor accepts responsibility and has no liability for the information
provided herein (or any reliance placed thereupon). This document does not constitute legal or
professional advice and must not be relied upon as such.
.

From: Adeline Courbet – UNIVAR SOLUTIONS


Sent: Tuesday, June 4, 2024 5:45 PM
To: support - dow
Subject: UNIVAR SOLUTIONS_00201188

Good Afternoon,

For the product XM PMX-200 SIL FLUID 1000CS, would it possible to provide a D4/ D5 /D6 statement
referring to the new Regulation (EU) 2024/1328?

Thanks.

Adeline Courbet

Univar Solutions EMEA Regulatory Lead

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