The German Federal Institute for Occupational Safety and Health (BAuA) has published a new brochure on REACH, Reach Info 6 on Products – Requirements of Manufacturers, Importers, and Dealers (REACH-Info 6 Erzeugnisse – Anforderungen an Produzenten, Importeure und Händler). The authors of the brochure define the terms substance/mixture and manufactured product, and differentiate each term from the other. They also describe the most important information and notification obligations of companies that produce, import, or deliver products in the context of the REACH regulation.
For example, if a product contains more than 0.1% of an alarming substance, suppliers of the product are obligated to notify their customers and the consumers. There may even be a reporting obligation towards the ECHA. The matter becomes particularly involved when one product is combined with other products into an even more complex product, as is the case with a computer. Is the computer now considered a new reference? Or is the reference to the parts, such as processor, cable, or housing, according to the idea that once something is a product, it is always a product? The authors prefer the latter approach and amplify their arguments graphically with multiple examples.
KFT has ensured compliance according to Article 40 of the CLP regulation for many customers yet fulfilling the reporting obligations. Please feel free to contact us if you have any questions concerning REACH and articles or products.