Importers: Take Notice

Anyone who wants to import chemicals or chemical mixtures into the European Union as of June 2018 must register the substances with the ECHA whenever the quantity involved exceeds one ton.

Uncertainty sometimes exists about imported articles. It’s true that an importer is not required to have such articles registered. But importers must have individual materials registered that are contained within the products and are to be deliberately released so that the function of the product can be realized. Fragrances in toys would be a good example. But registration is not required if another company has already registered the same substance for the identical purpose. A notification is required whenever a substance of very high concern is involved. But registration is not required if another company has already registered the same substance for the identical purpose.

Particular caution is required when the vendor has appointed a sole representative. That person is, of course, responsible for the registration. Nevertheless, companies must examine the representative’s reliability and regularly communicate with the representative and the vendor. For example, it would be important to know if the quantity being imported was actually included in the records of the sole representative. If the requirements to record or document are not observed, importers can lose their status as downstream users and have to undertake the registration themselves.

Please note that the REACH Regulation applies to all members of the European Economic Area. Accordingly, commerce between EU states and countries like Iceland, Liechtenstein, and Norway is not considered import or export.

You can find more detail information on this topic and on REACH 2018 in general here. The ECHA also provides some helpful guidelines.

KFT can also serve as a sole representative according to Article 8 of the REACH Regulation. Contact us at reach@kft.de.

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