REACH impacts the whole chemical supply chain. Whether you are a manufacturer, importer or downstream user, make sure you know your responsibilities to ensure continuity of supply. |
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Everyone in the chemicals supply chain has a role to play in the implementation of REACH. Each party needs to be aware of their respective obligations and prepared to communicate information on product usage and safe handling procedures, up and down the supply chain.
Customers
As a customer, it is important to ensure your supplier within the European Union (EU) registers the product for the ways in which you use it. In support of this, be prepared to provide information to your supplier about how you use the product. You should pay particular attention to the potential for human and environmental exposure.
Make sure you review the safe handling procedures proposed by your supplier and inform the supplier if these procedures are not applicable in your workplace. If your supplier is outside the EU, you may have obligations as an importer - see next section.
Importers
As an importer of a product into the EU, you may have registration obligations. Make sure you contact your supplier before the end of the pre-registration period, 1 December 2008, to determine whether you should (pre-) register, or whether your supplier has appointed an Only Representative who will register the imported substance instead of you.
If an Only Representative has been appointed then you do not need to (pre-) register. In this case you become a Downstream User, with the obligations as set out for customers in the preceding section.
Suppliers
As a supplier, you are required to understand how your product is handled throughout the supply chain. This information, in particular the potential for human and environmental exposure, will be required in your substance registration or that of the original EU manufacturer or importer.
