REACH for companies outside EU

[ivy.solomon]

Hi there.
i just attended a workshop on REACH yesterday and it seems that we fall under the role of Producer and Importer of Articles. our company is into surface finishing industry. we do service for plating.

is there anyone who has an idea if we need to register our articles to REACH? we only do plating services. the molded parts will be delivered to us by the customer, we do the plating and after that we send it back to the customer for them to assemble into finished product.

do you know how wide is our responsibility under REACH? i just called a testing lab and ask if they can do testing on REACH for the plated part and he said that we need to tell them what test we want because under REACH there are millions of substances to be tested and it will take about some time to do the test (and the cost is so high!)

please help.. help..

[harry]

Originally Posted by ivy.solomon

Hi there.
i just attended a workshop on REACH yesterday and it seems that we fall under the role of Producer and Importer of Articles. our company is into surface finishing industry. we do service for plating.

is there anyone who has an idea if we need to register our articles to REACH? we only do plating services. the molded parts will be delivered to us by the customer, we do the plating and after that we send it back to the customer for them to assemble into finished product.

do you know how wide is our responsibility under REACH? i just called a testing lab and ask if they can do testing on REACH for the plated part and he said that we need to tell them what test we want because under REACH there are millions of substances to be tested and it will take about some time to do the test (and the cost is so high!)

please help.. help..

Welcome,

Do you have an office in Europe to handle the import of your goods into any European countries? If not, how can you be an importer?

You mentioned that you do plating service - which means you are just providing a value added service and have no control over the final product. If that is the case, I think your responsibility is to provide information to your client on the various types of chemicals that may be present or that you use for processing (you should have these isn't?)

Anyway, have a look at the attachment: "Q and A on the new Chemicals policy, REACH" in this post.

Added in edit: you should be working closely with your chemical suppliers to ensure that they are supplying you approved material where possible, supply you necessary information and CSDS for your onward transmission to your clients.

[ivy.solomon]

hi harry,

thanks for the reply.

we dont have importer in EU and yes, we only do service.

so basically, the REACH will have great impact (and cost) to us?
and the bulk of the responsibility will fall under our chemical supplier?

[harry]

the REACH will have great impact (and cost) to us?

Provided the parts you value-add are exported to Europe. Otherwise, a lot of people (who do not export to Europe) had not heard of REACH yet.

the bulk of the responsibility will fall under our chemical supplier?

Many chemical suppliers in Asia do not export to Europe and it's business as usual for them. You would have great difficulty getting relevant information from them because they are in a market that doesn't require it.

[Kales Veggie]

I read your posts and trying to understand.

What do you mean with service? What are the links of your product with the EU?

Beside the export to EU concerns, you should also be aware of materials you purchase from the EU. If your EU supplier decides not to pre-register or register, this materials might become obsolete a few years down the road.

Take a look at the information here (aimed at automotive industry):

http://www.acea.be/index.php/news/category/reach/

Be aware a scare tactics (similar to what happened with Y2K). We should use our due diligence and determine if there is any impact on us and our products.

I am working with a client that is going through the same process (there are many that are doing this right now)