EU Restricted Substances, REACH/CLP & Product Materials Policy

Version 1.0 · Last Updated:

1. Purpose

This policy sets out Murzo Group's approach to EU restricted substances, REACH, CLP, substances of concern, chemical safety, material declarations, safety data sheets, and supplier controls.

The purpose is to reduce the risk of unsafe materials, illegal chemicals, incorrect hazard labels, restricted substances, misleading material claims, and goods being blocked or withdrawn from market.

2. Scope

This policy applies to substances, mixtures, articles, materials, packaging, textiles, coatings, finishes, adhesives, cleaning products, substrates, farming inputs, fashion goods, food contact materials, equipment, batteries, electrical items, and imported products supplied or used by Murzo Group.

3. Policy Position

Murzo Group will take proportionate steps to identify restricted substances, hazardous classifications, supplier responsibilities, safety data requirements, labelling needs, and country-specific material rules before using or supplying relevant goods.

Chemical, material, and safety claims must not be made unless they are accurate and suitable for the product and market.

4. REACH and CLP Controls

  • Check whether a substance, mixture, or article falls within REACH, UK REACH, CLP, GB CLP, or related local requirements
  • Check whether supplier safety data sheets, hazard labels, exposure information, or restriction statements are needed
  • Check whether substances are restricted, authorised, candidate-listed, or subject to specific limits
  • Check whether food contact, skin contact, child use, workplace use, or environmental exposure increases risk
  • Avoid importing chemicals or treated articles without understanding importer obligations

5. Supplier and Material Claims

Suppliers may be asked for focused material evidence where product type, market, or customer requirements justify it. Murzo Group will avoid broad data requests that are not needed for the decision being made.

Claims such as non-toxic, chemical-free, organic, vegan, hypoallergenic, biodegradable, recycled, low-impact, PFAS-free, BPA-free, phthalate-free, flame resistant, antimicrobial, or safe for food contact must be checked before use.

6. Restricted and Sensitive Materials

Additional caution is required for materials that may be toxic, allergenic, persistent, bioaccumulative, carcinogenic, mutagenic, reproductive toxicants, endocrine-disrupting, environmentally hazardous, explosive, corrosive, flammable, sensitising, or otherwise regulated.

7. Labelling and Safety Information

Where hazard labels, language, pictograms, safety data sheets, use instructions, exposure controls, disposal instructions, or emergency information are required, they must be suitable for the market and user.

Relabelling, repackaging, dilution, reformulation, or private labelling must not be used without checking whether Murzo Group becomes a manufacturer, importer, downstream user, or distributor for legal purposes.

8. Required Evidence Only

Material, chemical, supplier, safety, and compliance evidence should be limited to what is needed for law, safety, customer requirement, product compliance, authority request, insurance, or dispute handling.

9. Review

This policy will be reviewed when Murzo Group launches a new material category, imports chemicals, sells into a new regulated market, or identifies a relevant substance restriction.

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