Communication with your upstream suppliers and your downstream customers is a very important aspect of the REACH programme regardless of your status under REACH. For non-EU suppliers who have appointed an Only Representative, they should use their OR to guide them through the quagmire of upstream and downstream communications.
This can encompass two types of communication:
a) Seeking REACH Coverage
If the upstream supplier is the primary manufacturer of the substance, there may be a possibility that he has or will register the substance under REACH. The non-EU supplier could possibly obtain REACH coverage for his supply of the substance to the EU market. If so, the non-EU supplier should acquire written confirmation that his tonnage is covered by the upstream supplier registration.
b) Requesting composition data
For non-EU formulators and blenders that supply to the EU market, in some cases they will not know the full composition of the components that they include in their formulations. In cases where the upstream supplier is unwilling to disclose the composition details for confidentiality reasons, the OR can set up a Trustee agreement with the upstream supplier and protect their confidentiality concerns. The upstream supplier will then share the composition data with the OR and enable the OR to calculate the REACH obligations without disclosure of confidential data to the non-EU formulator.
Similarly, calculation of the REACH obligations for substances contained within polymers can be complicated depending on the monomer composition and also the presence of other reactants. It is recommended to use your OR to engage directly with your polymer supplier to calculate the REACH obligations for the substances present.
Downstream communications involves providing confirmation to your EU customers (importers) that the products they import are incompliance with REACH. There are a number of different types of REACH certification been used in industry varying from Product certification to Tonnage Import certificates.
The use of these certificates is not regulated under REACH and it is up to industry to decide on an appropiate form. Non-EU suppliers should use their OR to develop REACH certification for the products that they supply to the EU market. This certification can be used to reassure existing customers of REACh compliance and also potentially attract new business.
Need support with your REACH supply chain communications?
Then contact the experts at H2 Compliance for a 30 minute Free Consultation on your supply chain communication requirements or our Only Representative service and how H2 Compliance can assist with these supply chain communications by acting as your Only Represenative.
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