How to demonstrate REACH Compliance

R

Richard W

#1
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
 
Elsmar Forum Sponsor

qpled

Involved In Discussions
#2
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).
 
R

Richard W

#3
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

Involved In Discussions
#4
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.
 
Thread starter Similar threads Forum Replies Date
N How do I demonstrate REACH compliance ? RoHS, REACH, ELV, IMDS and Restricted Substances 1
R Demonstrate how sufficient levels of access to data is achieved - Claims of equivalence EU Medical Device Regulations 3
S Ways to demonstrate objective evidence that employee is trained and competent ISO 13485:2016 - Medical Device Quality Management Systems 28
S How can we demonstrate to MDSAP auditors that we have the requisite training ISO 13485:2016 - Medical Device Quality Management Systems 9
S What are some ways to demonstrate Effectiveness of Training? ISO 13485:2016 - Medical Device Quality Management Systems 29
C Unable to Demonstrate FIFO Methodology ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 8
A Action to demonstrate compliance with on clauses 4.1, 4.2 and 6.1 of ISO 9001:2015 ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 6
B How to Demonstrate Stability and Repeatability in very Short Run Process AS9100, IAQG, NADCAP and Aerospace related Standards and Requirements 10
S What needs to be done to demonstrate RoHS compliance for Medical Devices? RoHS, REACH, ELV, IMDS and Restricted Substances 6
J How to demonstrate equipment manufacturer meets 7.6.3.1? IATF 16949 - Automotive Quality Systems Standard 2
S QMS to demonstrate Compliance to Canada, Europe and Japan Other Medical Device Regulations World-Wide 7
C Statistical Analysis to Demonstrate Substantial Equivalence to the FDA Other US Medical Device Regulations 5
Q ISO 9001 Clause 8.3 Rework Verification - Re-verification to demonstrate conformity ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 6
J Continuous Improvement SOP - How to demonstrate we meet TS 16949 Clause 8.5.1 IATF 16949 - Automotive Quality Systems Standard 12
H Measure and Demonstrate Product Sustainability Sustainability, Green Initiatives and Ecology 0
P Resource Management - How to demonstrate Provision of Resources? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 8
L Contacting Suppliers to demonstrate Environmental Commitment ISO 14001:2015 Specific Discussions 3
L How to demonstrate one's ability in an interview Career and Occupation Discussions 8
V ISO 9001:2008 - How does an organization demonstrate "sustain success"? General Auditing Discussions 14
Q How to Demonstrate Manufacturing Process Design Conformity - Capability IATF 16949 - Automotive Quality Systems Standard 6
I In OHSAS 18001:2007 How to demonstrate 4.4.3.2 Participation and Consultation ? Occupational Health & Safety Management Standards 3
Ajit Basrur How to demonstrate Safeguarding of "Intellectual Property" in an Organization? Other ISO and International Standards and European Regulations 7
J Demonstrate Receiving Inspection Sampling Method is Statistically Adequate Inspection, Prints (Drawings), Testing, Sampling and Related Topics 3
K How can I demonstrate meeting 5.6.2.1 and 6.3.1 of ISO/TS16949 requirements? IATF 16949 - Automotive Quality Systems Standard 2
P How to demonstrate cycle time minimization of rejected product/test analysis 8.5.2.4 IATF 16949 - Automotive Quality Systems Standard 10
M Gap analysis to demonstrate that we comply to CAN3-Z299.3-85 Various Other Specifications, Standards, and related Requirements 19
B How to demonstrate management commitment? Audit Failure Mode ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 4
L Internal Auditor Objectivity - How to demonstrate Miscellaneous Environmental Standards and EMS Related Discussions 10
R ISO 14001 Clause 4.4.4c - Interaction of Main Elements: How to Demonstrate? ISO 14001:2015 Specific Discussions 4
J Demonstrate 12 months performance data for TS 16949 Certification - Required? IATF 16949 - Automotive Quality Systems Standard 5
Raffy How can I demonstrate evidence and effectiveness of Corrective Action Training Nonconformance and Corrective Action 7
F Change to Formulation due to Reach (China Medical Device Regulations) China Medical Device Regulations 0
C Difficulties getting RoHS/REACH for cheap parts RoHS, REACH, ELV, IMDS and Restricted Substances 1
P How far an operator can reach into a machine before it becomes an ergonomic problem CE Marking (Conformité Européene) / CB Scheme 5
M EU – REACH Authorisation Decisions List REACH and RoHS Conversations 0
M EU – Chemical Safety Report – CSR – REACH Authorisation decisions – Triton X-100 – Ortho-clinical-Use1 REACH and RoHS Conversations 0
Nicole Desouza Who has to be compliant with REACH Declarations? REACH and RoHS Conversations 11
J Where can I find the latest update to Reach and ROHS? REACH and RoHS Conversations 7
padraick63 REACH and ROHS Requirement for a Molded Part REACH and RoHS Conversations 1
R Certificate of compliance to RoHS/REACH/WEEE - any such animal? REACH and RoHS Conversations 18
T MSDS Language Requirements for Reach Purposes REACH and RoHS Conversations 3
S IMDS=REACH for automotive industry? REACH and RoHS Conversations 3
L REACH Compliance - Small, family-owned contract manufacturer REACH and RoHS Conversations 16
R REACH and ROHS compliance for hundreds of parts made over 25 years REACH and RoHS Conversations 3
P REACH - BOMcheck.net - What I can expect from this service? REACH and RoHS Conversations 0
P REACH - A few of the hundreds components in my product no longer meet requirement REACH and RoHS Conversations 2
C SVHC Lead - Communicate in the supply chain under Article 33 of the REACH Regulation REACH and RoHS Conversations 1
D How do I show compliance to RoHS, REACH and Conflict Minerals? REACH and RoHS Conversations 6
J RoHS, WEEE and REACH Consulting Expertise Needed REACH and RoHS Conversations 4
P Necessary Compliance Documentation for RoHS and REACH REACH and RoHS Conversations 5

Similar threads

Top Bottom