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Other issues affecting downstream users

Other issues affecting downstream users

DU and Reach registration

If you rely on chemicals for your operations in the EU, you may be affected by the REACH registration deadlines.The last deadline for registering is on 31 May 2018 and in the EU / EEA between 1-100 tonnes per year.

If suppliers have not been registered by May 31, 2012, However, you can take action to protect your business.

1. Identify substances critical to your business

  • This includes substances in mixtures. If you are interested in this article, please do not hesitate to contact us.
     

2. Check if the substances are already registered. 

  • Registered substances are listed on ECHA's website. You can also see who has registered them.
     

3. Check if the substances should be registered

  • It is likely that a substance should be registered if your supplier manufactures or imports more than one tonne per year. Certain types of substances have no registration obligations such as naturally occurring substances or substances that are subject to registration or licensing under other legislative regimes such as substances in food.
 

4. For any substances not registered, find out if your suppliers plan to register them. 

  • Keep in mind that a positive response or pre-registration is not a guarantee that the supplier will go on to register a substance.
     

5. Look for alternative suppliers if necessary. 

  • Companies that have registered the substance can be found on ECHA's website.
     

6. Check that your uses will be covered in the registration, particularly if you use a substance in a novel way.

  • Users of chemicals have the right to inform suppliers on their uses so that they are covered in the registration. This helps to ensure your use is covered in the exposure scenarios you receive later on.
  • If you operate within an organised sector, your sector organisation may have generated use maps that describe typical uses and conditions of use in an agreed format that registrants can use easily. This saves time as it is not necessary to contact your supplier directly. 
 

7. If no supplier intends to register a substance, consider importing it directly. 

  • If you import more than one tonne of a substance per year, you need to register it. 
  • Registration requirements are less comprehensive for quantities up to 10 tonnes per year.

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