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Communication in the supply chain – REACH as the regulatory driving force

corresponding

PETER E. T. DOUBEN
REACHWise Ltd, London, United Kingdom

Abstract

Under REACH, a major piece of EU chemicals legislation, substances will need to be registered in every supply chain unless exemptions apply. Two different issues benefit from effective communication in the supply chain. The first one is the issue of identified use in the supply chain which is important to ensure that a registration dossier is complete and covers as many as possible different types of uses while also enabling downstream users to inform registrants about the manner in which substances are used so that these can be risk-assessed. The second one is the issue of ensuring compliance with registration for products which is in the interest of downstream users who themselves do not have registration obligations. IT-platforms are indispensable to perform these tasks efficiently and effectively.


INTRODUCTION
REACH is a major piece of EU chemicals legislation which has been in force for just over a decade (1). A key element is the registration of individual substances, a process which has been phased in over a number of years and it has recently been concluded by the registration of the lower tier tonnage bands (1 -10 and 10 – 100 tonnes per annum (tpa) per legal entity) completed by manufacturers, importers and Only Representatives of non-EU suppliers. In principle each substance needs to be registered in a supply chain unless exemptions apply. While the onus is on those aforementioned actors in the supply chain, for certain pieces of information such as details of use information further down the supply chain they require information from Downstream Users (DUs). Furthermore DUs may want reassurance that the substances they are using in their products have been registered. These two elements form the backdrop to essential communication in the supply chain.

 

REACH REGISTRATION ASPECTS IN THE SUPPLY CHAIN

REACH has established procedures for collecting and assessing information on the properties and ...




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