What is your responsibility under REACH?
REACH Only Representative Service
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If you manufacture, import, or use chemicals, or import articles,
the pre-registration period 1 June 2008 – 1 December 2008
is a critical time for your business. Companies from outside the EU can not register substances themselves, they can appoint an Only Representative within EU.
Compile an inventory
Build an inventory of every chemical that comes into, is part of, or goes out of the business - what feedstocks, intermediates (isolated or otherwise), and products are used or created?
You need to know all the substances you use; for preparations you need to find out what the ingredients are. Keep a record of each one, and include essential information for example the name of the chemical and the percentage in any preparations. You can use this information to determine the tonnage per year.
Additionally you need to know whether you produce or import articles. If you do, establish if any substance (which is intended to be released under normal or reasonably foreseeable conditions of use) is present in these articles in quantities totalling over 1 tonne.
Once this inventory has been established, you can begin to understand what substances you rely on, and consider the impact on your business should REACH influence the supply (or for registrants, the production or import) of a substance. Consider contingencies, for example alternative supply, routes, chemicals or processes, or supporting suppliers in their REACH obligations, etc.
Every business making use of chemicals that aren’t exempt from REACH needs to understand how valuable these substances are to them, and plan to make effective business decisions based on this knowledge. Consider the importance of each substance to your business. Ask yourself the following sorts of question:
- What do you use it for?
- Are the uses to which you put chemicals going to be supported by their registrants?
- How much of it do you use?
- Are there any alternative substances or processes that could replace this?
- Will your supplier/s maintain supply of important substances if REACH impacts the commercial viability of doing so?
- What will be the impact for you if the price increases or the supply drops, and what can you do about it?
- Do you want to share information back to registrants about what you use chemicals for, or is this information so sensitive that you would prefer to compile risk assessments yourself, and submit these directly to the European Chemicals Agency? What will this involve?
- Identify any chemicals that may be 'substances of very high concern'.
- Determine your role in relation to each substance on the inventory.
Establish a relationship with your suppliers and any downstream users. You need to know how REACH is going to impact on your supply chain before you can decide what to do about it. Identify an appropriate person as the main REACH contact in your organisation and make them the focus for communications with suppliers and customers.
Six Main Steps to REACH:
- Inventory of Substances
- Submit xml file on REACH-IT
- Join Pre-SIEF, SIEF, Consortium
- Registration Dossier preparation
- Registration Submission
Need more information or assistance?
Let Wellkang be your REACH Only Representative and
Pre-register your chemicals under REACH regulation in EU!
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