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Conflict Minerals - Tin Suppliers CMRT

SpinDr99

Involved In Discussions
#11
Thanks so much for your replies. I've advised the company doing REACh compliance for our customer that I found this on the ECHA site:

You do not need to register if you only:

  • distribute a substance: you store and place substances on the market, on their own or in mixtures, for third parties.
However, they are still requesting we complete the distributor reporting (We are a simple buy/resell distributor, no testing/assembly). None of the products we sell are above the threshold. I can get a listing of components we sell to each customer, but do I solely determine which parts have the 3TG content from my suppliers?

Again, I thank you greatly for your help!!!!
 
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Tagin

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#12
We are a simple buy/resell distributor, no testing/assembly
Many distributors (US-based) that we work with do not consider it their responsibility to provide REACH declarations; instead they refer us to the manufacturers of the products they distribute for that information. Often, the distributors only have a Yes/No value for the REACH compliance of each product, which they get from the product manufacturers; the distributors rightly don't want to take on any liability.
 
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