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Manufacturers and Importers
Non-EU manufacturers and importers
1. Manufacturers and Importers: Your obligations regarding REACH regulation
*Dependent on your production volume and hazards and risks of your substances
The first step: Analysis of your situation
- To make inventory of substances and preparations that you produce or import (collection of all substances data)
- To have an overview of your compositions and tonnages
- To have an overview of your customers
- To know what is your role in the supply chain
- To start identifying uses in the supply chain
Consult your local SGS contact for REACH Compliance!
Actions list
Check whether substance data is sufficient (SIEF)
- Animal test is not encouraged → data sharing if available
- If animal test has to be conducted, test proposal is required
Registration for substances > 1 t/a per manufacturer/importer
- Technical dossier for substances (with information on the substance and information on risk management measures) > 1 t/a
- Chemical Safety Report for substances > 10 t/a
We also have the option to delete the following: “Check whether substance data is sufficient (SIEF)” and “Registration for substances > 1 t/a per manufacturer/importer”.
For substances in articles
A. Registration required if:
- Substance intended to be released
- Substance is present in quantities > 1 t/a
B. Notification required if:
- Substances required for authorization (Substances Very High Concern)
- Substance in article with concentration > 0.1% (weight/weight) in a homogeneous material
- Substance is present in article in quantities > 1 t/a
2. Non-EU manufacturers and importers: Your obligations regarding REACH regulation
- Appoint an only representative by mutual agreement
- To fulfill obligations on your behalf
- Shall inform along the supplier chain regarding the appointment
- Only representative obligations:
- Have sufficient background in the practical handling of the substance
- Shall keep available and up-to-date information on quantities imported and sold to customers
- Shall keep available the latest safety data sheet (according to Directive 2001/58/EC).
Commission Directive 2001/58/EC of 27 July 2001 amending for the second time Directive 91/155/EEC
For REACH compliance:
Consult your local SGS contact
Download our REACH brochure and pocket flyer - NEW!
Download our Regulatory Bulletins (REACH Legislation)
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