Coping with your customer's information requests - what does REACH demand?
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Many of our downstream user clients have been overwhelmed by complex requests from their customers asking for a great deal of information and arguing that REACH requires it. It’s true that REACH expects the supply chain to be the route for information exchange and there are some very definite REACH obligations which should be respected, but many of the requests go far beyond REACH. This briefing note should help everyone understand what they must do - as part of complying with REACH, and what they might do – as part of keeping their customers happy! So from here on MUST means REACH demands it, MIGHT means it’s a matter for you and your customer to agree what is right for your business relationship. |
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What are your REACH obligations?
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As a downstream user you are no doubt worried that your supply of chemicals might dry up as a result of REACH, perhaps if a vital substance is not registered. So it’s reasonable to ask your supplier what the pre registration position is. And you in turn may be asked the question by your customers. Our template letters will help you do this.
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Under REACH it is illegal to market a substance subject to registration without an appropriate registration. A registrant MUST give customers details of the registration (and those in the supply chain MUST pass this on). For a substance which is subject to pre registration the REACH obligation is not so clear. So we say the pre registrant MIGHT give the pre registration number or an assurance that the substance is pre registered and that full registration is due at a certain date. In fact we think this makes good business sense and we would be worried about a supplier who refused to give the number or an assurance. But there is no obligation under REACH.
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Many customers are asking for details of upstream (pre) registrants. This is NOT required under REACH. Nor is the full disclosure of a formulation. Both of these MIGHT be disclosed, and it would be sensible to think of confidentiality agreements if you decide to do so.
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| Many formulators and finished goods (termed articles under REACH) manufacturers are being asked to disclose the presence of specific SVHCs* – often based on lists rather similar to Appendices 1-6 in Annex XVII of REACH which identify CMRs**. The presence of one of these in a preparation MUST usually always be disclosed, this is nothing new. But in the case of articles then the article supplier MIGHT disclose the information, but until the REACH Authorisation Candidate list is opened (probably at the end of the year) there is no obligation for article manufacturers or importers to disclose anything of the substances used to make the finished good you sell to your customers at this stage. |
* SVHC = Substance of Very High Concern
** CMR = Carcinogenic, Mutagenic or Reproductive toxic substances
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| Need some help? |
| If you think REACH applies to you then the clock is ticking and the time to get ready is now. Why not "Join for free" to access exclusive information that will help get you started. And if you, your cutomers or suppliers are still unclear what to do, upgrade to our Gold service and let us help. |
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