Keeping track of the amount of each substance you import is vital to ensure that you are compliant with REACH.
The trigger for requiring a REACH registration is 1t per annum so specific monitoring of substance close to the threshold is crucial.
Other important thresholds, 10t, 100t etc. also need keen scrutiny to ensure that REACH registration tonnage bands are kept up to date. If your imports for a specific substance exceed the tonnage band you have registered under a ‘Spontaneous Update’ should be carried out to increase the tonnage band of your registration.
In addition to monitoring the imports of individual substance it is important to monitor the import quantities of individual components in mixtures. For example if you import several dyes all containing sodium sulphate, you need to track the quantities not only of the individual dyes but the sodium sulphate. The volume of substances included in more than 1 product can quickly accumulate to >1t.
If you are a downstream user it is your responsibility to ensure that your suppliers hold the required REACH registrations. For suppliers outside of the EU the registration must be held by an Only Representative.
In the Sodium Sulphate Example above, if each product was supplied from a different supplier, each supplier could justifiably claim that they do not need a REACH registration for Sodium Sulphate as the amount supplied is <1t per annum.
In this case the following options are available to you:
- Request that your suppliers register Sodium Sulphate under REACH themselves or using an OR if they are outside of the EU
- Carry out a REACH registration for Sodium Sulphate yourself
- Reduce your imports so that the cumulative amount of Sodium Sulphate is <1t per annum
It is worth noting that suppliers may simply state that their substances are REACH compliant. This does not always provide sufficient information. As can be seen from the earlier example, whilst each supplier could claim to be compliant with REACH you might not be. The onus is on the Downstream user to collect enough information to ensure that they are compliant.
Tonnage Tracking Service
Collating and maintaining this information can be time consuming and complex. Our in-house database system enables us to keep track of quantities.
We provide regular reports highlighting any areas of concern to assist your forward planning and enable you to take any necessary action to remain compliant.
We have a bolt-on service to monitor any substances of interest for SVHC and regulatory updates using industry standard software.
Contact us on +44(0)1484 866777 or firstname.lastname@example.org to discuss how we can help you.