Got this letter from Swix:
HF & LF WAXES HAVE BEEN APPROVED
Dear Valued Dealers and Partners,
As the ski season nears, I am extremely pleased to announce that all Swix and Toko waxes shipping this Fall have been cleared for compliance with the U.S. Environmental Protection Agency’s (EPA’s) requirements under the Toxic Substance Control Act (TSCA). This includes all HF and LF fluorinated glide waxes, kick waxes, liquid waxes and cleaners.
During the last two seasons, the EPA has been conducting a nationwide compliance and enforcement initiative centered on examining the chemical ingredients in ski waxes and cleaners. This initiative is part of a broader program to examine the use of perfluorinated chemicals in consumer products. All chemical substances in consumer products, including ski waxes and cleaners, must be reviewed and approved by the EPA prior to use.
The EPA regulates the use of chemical substances in consumer products through the Toxic Substance Control Act of 1976. Under TSCA, the importer (or U.S. producer) of a chemical product must certify that every chemical substance in product complies with all TSCA regulations. It is not enough to simply ask the upstream supplier if their mixture or substance complies with TSCA, or to assume that substances and mixtures approved for use in Europe are also compliant with TSCA. The EPA expects the importer/producer to independently verify compliance with U.S. law by checking the identity of individual chemical substances against a list of substances called the “TSCA Inventory” or by obtaining certain types of written documentation of compliance from the supplier.
Swix USA recently completed an extensive review of all the chemical substances contained in their products and obtained the necessary documentation to ensure 100% compliance with TSCA, Toxic Substance Control Act. This long, investigative process caused a delay in SWIX and Toko’s ability to fulfill shipment of certain products during the 2018 - 2019 season, but it was necessary to undertake the process to verify 100% compliance with TSCA for all our products. To those customers who have had orders impacted by the delay, we understand and share in your frustration and we sincerely apologize for any disruption in your business.
In our efforts to be 100% compliant and to protect our retail partners - we encourage everyone to ask your suppliers if they have undertaken the type of supply chain investigation necessary to verify and document 100% compliance with all applicable US laws and regulations. If they are not able to confirm in written documentation that they (or their suppliers) have checked the identity of the individual chemical substances in their products against the TSCA Inventory, then they have not done what EPA requires to comply with the law.
In addition, Safety Data Sheets (SDS) for all Swix and Toko waxes and cleaners are in compliance with OSHA’s (Occupational Safety and Health Administration) workplace hazard communication requirements and other regulatory requirements such as California Proposition 65 (a California law that requires proper labeling and warnings for certain products sold or shipped in the state of California). The SDSs include a statement on TSCA compliance and provide important information for safely using our products. Safety Data Sheets (SDS) for all Swix and Toko waxes and cleaners are available at www.swixonline.com.
As some of our waxes required packaging updates, they were not included in your June, July or August preseason shipments. Shipments of these waxes will begin shipping late September from our Massachusetts warehouse facilities.
Should you have any questions or concerns please don’t hesitate to contact your local Swix and Toko sales representative or to reach out to us directly at 1.800.343.8335. We value our relationship with you and look forward to a successful season!
Steven Poulin // President & CEO of Brav USA
SWIX SPORT | 60 Newark St | Haverhill Massachusetts 01832
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