Is It Necessary to Embark on REACH

Q

qalsang

#1
Hi
Pls enlighten me on this REACH program

We bought raw material from material suppliers and convert these
materials to different shapes & sizes for our final customers.
When customers requires us to fill up REACH survey forms , we will
get the necessary information from our material suppliers and pass it
to the customers.

In these context , do we still have to go through the entire REACH process
 
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P

prototyper

#2
Do you import your product directly into the EU?
It is the responsibility of the importer to ensure that the chemical composition of the product is registered under REACH.

If you do not directly import, your responsibility will be to pass on the chemical composition from your suppliers to your customers.

See the attached link for the UK Health and Safety Executive which will explain the responsibilities for REACH in more detail http://www.hse.gov.uk/reach/role.htm
 
B

Balu Sharma

#3
You need to embark upon it to the extent that your customers are impacted!

It depends on whether you and your customers would classify as formulation (mixed chemicals) manufacturer or article (e.g laptop0 manufacturer.

If your customers are article manufacturers, they are under obligation to inform their customers about existence of the 15 SVHC identified recently (Substance of Very High Concern) above 1000 PPM. This is REACH article 33.

Your customers, in turn will ask you about existence of these substances in what you sell to them.

if you provide chemicals to your customers, then the chemical has to be registered either by them or by you. So they will ask you if you have registered it/or plan registering it.
 
N

Nanty

#4
As said before, you should check whether you deliver into EU a substance (e.g. copper), a preparation (mixture of substances e.g. cleaner) or an article (product e.g. a bucket or a pencil).
Any registration should be done by a legal entity residing in EU. That can be the importer, an only representative (OR) whith whom you agreed to deal with the registration or yourself having a legal entity in EU.
Most substances (there are some exceptions) should be registered (if you did not so far, then you can not sell before the dossier is filed and authorized).
If you supply a preparation then check with your supplier whether they have registered. If yes, no problem. If no, then you have to ask the supplier to register or register yourself (which will not be easy!).
If you sell an article, you need to check whether the article has an intended release, like with a pencil or a cartridge. If not, then you only need to inform your customer and (depending on quantity of usage) ECHA if you use SVHC (substances of high concern - google "echa candidate list" - I am a new writer and can net add links) in the article. If you sell an article with intended release, then you have to check whether the substance which is released, is registered. If not, check handling substances as said before.
REACH is the largest EU legislation so far. The law itself covers over 200 pages and together with all the explaining pages (also official EU origin) one has to conquer 10.000 pages. So, better get some advise.
 
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