How to demonstrate REACH Compliance

[Richard W]

Hi All.

We are an importer / distributer and we get good from the far east and the UK, so judging from the below statement we need to comply with REACH

Importer: If you buy anything from outside the EU/EEA, you are likely to have some responsibilities under REACH. It may be individual chemicals, mixtures for onwards sale or finished products, like clothes, furniture or plastic goods.

My question is how would demonstrate compliance?

We totally rely upon suppliers so is it a case of getting them all to confirm in some kind of declaration (similar to the packaging essential requirements around heavy metal content of packaging)

We have over 1000 suppliers so I am hoping to do this as efficiently as possible.

any suggestions would be great.

Thanks

Richard

 

[qpled]

For REACh compliance I wait until a customer request comes in and then check with the suppliers that produce that specific part or parts. If you are in the situation where all of your 1000 suppliers are supplying parts that you use to make a few products, then you will need to send out a request to every supplier, or hire a third party to do so for you (I receive both - requests from customers and requests from third parties hired by my customers).

 

[Richard W]

Thanks but isn't that a bit late and after the event? - unless you get requests prior to providing the products?

Is that approach the norm and considered acceptable?

I'm just thinking it is not really assuring compliance - if someone asked you want your compliance rate for REACH would be - you would have to state it along the lines of "99% compliance for the instances we look into".

Don't get be wrong - I would prefer this option as it sound easier. However if a customer asks me how we manage REACH - my answer would be - we check compliance for the products we are asked to do so for - which doesn't sound great - unless we can dress it up a bit?

Thanks

Rich

 

[qpled]

Since REACh is dynamic and not static (new chemicals continue to be added to the list) I have customers who check in with me both before and after purchases are made. I have it easier than you since I am working with fewer suppliers and many of them post their REACh compliance statements on their websites. With 1000 suppliers you may need to use a third party to keep up with the constant changes to the REACh list.