REACh - Duties of manufacturers, suppliers and users of products
Products have a special status under REACH. There are certain conditions for producers, suppliers and users of products under REACH such as information and notification requirements and the obligation to register substances. The product itself must not be registered. However, there is a registration requirement, if a substance which is to be released exceeds the amount of this substance in the product by 1 ton per year. This figure includes the total amount of the substance in all products of the importer or producer. The total amount is composed of the released and of the amount that (still) remains into the product.
Companies that produce or deliver products, have also notification and information obligations to the customers, distributors, users or consumers of their products. In certain cases, there are also obligations towards the European Chemicals Agency (ECHA). The information requirements are subject to those producers, processors and importers which use products containing substances of very high concern (SVHC) or deliver such products to a purchaser or consumer. Those substances may have carcinogenic or mutagenic characteristics or may be toxic to reproduction.
In the case of products contain more than 0.1 percent of SVHCs, the supplier provides the recipient of the article with information about the safe use of the article or, as a minimum, the name of the substance. The same information has to be provided to the consumer, but only upon his request. The information is to pass in the appropriate form to the customer. The transmission of information is usually done on paper (e.g. in the official language of the destination country). Moreover, it is possible to publish additional information on a website or to pass it via email.
REACh - Definition and importance to manufacturers, distributors and importers
REACh fundamentally differs in substance, mixture (preparations) and products. A substance is therefore a chemical element (such as metals and minerals). Mixtures or preparations are defined as a mixture, mixtures or solutions composed of two or more substances (e.g. lubricating oils). For manufacturers of products and devices, however, the definition of products under REACh is very important. Accordingly, a product is an "object which is given a special shape, surface or design during production that determines its funktion even more than its chemical composition does. Products such as electrical and electronic equipment are therefore defined as products within the meaning of REACh. Thus, basically every company can be affected by REACh, whether as a manufacturer, importer of equipment from the EU area or as a manufacturer/importer of products. Also distributors of products are not exempt from the obligations under REACh.
REACh – Registration, Evaluation, Authorization and Restriction of Chemicals in electrical and electronic equipment
For many products and devices of everyday life there are no information about the chemical substances contained therein. For this reason, on 18 December 2006, the final version of the REACh Regulation (1907/2006/EC) was adopted in the European Parliament and entered into force on 1 June 2007. Since it is an EU regulation, it applies automatically, without conversion as a national law in Germany. REACh regulates the Registration, Evaluation, Authorization and Restriction of Chemicals. The chemical industry (manufacturers and importers) and even importers and distributors of products and articles are effected by REACh.
REACh - Goals and Objectives
Since REACh came into force manufacturers and importers are responsible for the safety of the chemicals in their products. They even have to obtain and supply the necessary data to assess the riskiness of their products. You must demonstrate convincingly that all materials can be handled safely by all users and neither endanger the health of users or consumers nor contaminate the environment too much.
REACh solutions by take-e-way
- take-e-way offers together with accredited partners specifically developed consulting services for distributors and importers who want to comply with REACh.
- Trainings: In cooperation with its partner foundations take-e-way offers individual trainings and knowledge about the contents and tasks of REACh and gives you advice on how to comply with the requirements of REACh.
- Individual counsulting: In the individual consulting, we advise you to combine the imparted knowledge with the specific needs of your company in order to comply with REACh. This does not require an expensive materials database: We simply build upon the existing operations and product knowledge of your company. If you are interested in our modular REACh solutions, please call us at the telephone number +49(0)40/750687-0 or send us an email.