Coping with your customers' 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 for the substances you buy from them; our template
letters can help you with this. Of course, your customers in turn may ask you the same question.
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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 that is subject to pre-registration there is not such a clear REACH obligation. So we say the pre-registrant MIGHT give the pre-registration number or at least an assurance that the substance is pre-registered and that full registration is due by a certain date. Giving such a declaration probably makes good business and keeps customers happy, and we would be worried about a supplier who refused to give good assurance about the pre-registration status of a substance.
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Many customers are asking for details of upstream (pre-) registrants. This disclosure is NOT required under REACH. Nor is the full disclosure of a formulation. Both of these MIGHT be shared, but it would be sensible to think of confidentiality agreements if you decide to do so.
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| Many formulators and manufacturers of finished goods (termed articles under REACH) 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 substances in a preparation MUST normally be disclosed, which is nothing new. In the case of articles, the article supplier MIGHT disclose the information; if and when the particular substance is included on the REACH Candidate List of Substances of Very High Concern for authorisation the supplier MUST usually disclose information on that substance present in the finished goods they sell to their customers. |
* SVHC = Substance of Very High Concern
** CMR = Carcinogenic, Mutagenic or Reproductive toxic substances
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