Glossary
- What is REACH?
- REACH Registration
- Only Representative
- MSDS
- IUCLID 5
- CoSHH
- EUROTOX and training
- INCI and labelling
- TIF
- SIEF
- Toxicology
- Regulatory Compliance
- Training in regulatory standards
Do you need help with any of these issues?
Then please use our contact form to get in touch, or phone Cliff Betton on +44 (0)1252 836 550
REACH for Importers
Manufacturers outside the EU may be reluctant to divulge the content of their products.
Under REACH however, it is the importers' responsibility for ensuring compliance, not that of the non-EU supplier of the goods. If for example, a major retailer in the EU imports a range of goods from manufacturers outside the EU then the retailer is responsible for the total quantity of the chemicals that are being imported, not just the amount of chemical being imported per product.
A retailer may bring in several hundred different types of products during a 12-month period, each of which may contain potentially a number of common ingredients.
For example, sodium lauryl ether sulphate may be found in shampoo, bath and shower gels, toothpaste, household cleaners, washing up liquid, car cleaning products and so on. In any one product-range, the amount of SLES imported may be below the one tonne per importer, per year. But should the total amounts of SLES bought into the EU across the range of imports be considered, the single retailer could be importing SLES over 100 tonnse per year, which triggers a REACH obligation.
Importers therefore need to know exactly how much of all chemicals, across all product ranges, they are bringing into the EU:
- How much product does an importer buy on a year-by-year basis from each non-EU supplier
- What the formulation is of each product bought in order to be able to calculate the total amount of each chemical substance imported across all product ranges.
It will not be enough for a retailer or other importer of multiple products to obtain reassurance that none of the ingredients will require REACH registration from a supplier, as this will not address their overall obligation.
Delphic HSE have produced a REACH Tool to assist those companies wishing to calculate their REACH obligation.
If however, companies exporting into the EU appoint an Only Representative to assume all REACH responsibilities for chemicals that they export to all customers within the EU, the Only Representative, acting on information supplied by the manufacturer, takes on all of the REACH Responsibilities for all chemicals supplied into the EU in quantities greater than one tonne per year.
If suppliers appoint an Only Representative, there is no obligation on the importer and no requirement to divulge confidential information to anyone other than to their representative.
Delphic HSE's Only Representative service can maintain confidentiality and ensure regulatory compliance for non-EU suppliers.
Contact us.