Hi all, just wondering if anyone can give me any advice regarding this REACH legislation and weather we are required to register to it?

We are a small service and calibration company which specialises with Co-ordinate measuring machines. We are increasingly being asked by our customers to sign up to this REACH legislation. However i am unsure if we are required to do so. We do not produce any components but rather offer a calibration service and only the only chemical we use is a small amount of methylated spirits to clean the machine prior to it being calibration.

Therefore, are we still required to register??

I do not think so. Only raw material suppliers can register their substances.

Your "spirits", if produced in the EU, must be registered by the manufacturer.

OEMs have been sending out standard mass mailing letters to all their suppliers.

IMHO you don't have to register ( it's too late to pre-register now ) as you deliver services, not articles, preparations or substances.

And your cleaning product may contain SVHC's ( ask your supplier ) but I don't think you will be using over one tonne per year ( per SVHC substance in the product )

Best regards,

Antoine

You do not have to do anything as you do not produce an article containing a chemical intended for release during the normal use of the product. The problem with REACH is that the majority of Companies do not understand the requirements of REACH and just pass it up the supply chain.

As an example: If you sent the calibrated equipment back with a bottle of lubricating oil then you would need to supply (if asked) REACH information as provided by your upstream supplier of the oil.