Downstream users of chemicals - Actions to take now in the first year of REACH

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Managing The Impact On Your Business

Since the regulation came into force on 1 June 2007, it has become clear that REACH will have a major impact on the users of chemicals.  There is the possibility that some chemicals will be withdrawn from the market for a variety of reasons - economic and regulatory, others may be restricted in their use.  All users should be assessing the business risk.  Early action can be taken to ensure that the arrival of REACH does not compromise production or product continuity.  Here's how to get started...

 
  1

Check out your REACH status

Confirm that you are not a manufacturer or an importer of substances as well as a user. 

If you are a manufacturer or importer you will need to take additional action - our website contains a lot of information to help you - Click here to see the steps you will need to undertake to REACH register your substances.

 
         
  2

Decide what kind of user you are

Do you solely use chemicals to run your processes or are the chemicals you buy an intrinsic part of your products?

If the former is true complete only step 3 - but if the latter you will have to complete both steps 3 and 4.

 
         
  3

Review the status of the chemicals used in your processes

Match the chemicals you use to your processes and prioritise those which are essential for business continuity.  You need to ensure that your use of each of these substances is included in its REACH registration dossier. 

Liaise with your supplier on this, it may be necessary for them to work up the supply chain to the firm with the responsibility to register. If the registrants do not intend to include your uses in the registration, then your production processes may be at risk.

Prioritise the substances for urgent follow-up action and seek expert advice.  There are a number of ways to deal with this situation - REACHReady can help you to identify the solution that is right for you.

 
         
  4

Review the status of the chemicals used in your products

Identify the products in your range that are defined by REACH as substances or preparations.  Also identify any products defined as articles from which the component substances are likely to be released into the environment in normal use (for example, ink in a pen, toner in a print cartridge). 

Gather information on the use of your products from your customers.  Liaise with your suppliers to ensure that these uses will be part of the registration (as in step 3, your suppliers may need to work up the supply chain to the firms with responsibility to register). If the registrants do not intend to include these uses then your business continuity may be at risk.  Prioritise the substances for urgent follow-up action based on expert advice. There are a number of ways to deal with this situation  - REACHReady can help to identify the solution that is right for you.

 
Other information available in our REACH - the basics range: The Basics of REACH Registration for Manufacturers and Importers Your REACH Basics Summary
 

Our Silver and Gold subscribers can download our REACH the basics information in pdf form from the Technical Downloads section of our website - for access either "Join for free", or "Login" if you're already a REACHReady subscriber.

 
 
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