Summary of issues after completing the EU REACH registration

Release time:

2021-02-26 14:19

After EU REACH registration, what are the responsibilities and obligations of the registrant? How is the subsequent trade compliance?

Summary of issues after completing REACH registration

Q: What are the responsibilities and obligations of the registrant after completing the REACH registration?

1. Notify the customer that you have completed REACH registration, inform the customer of your contact information of OR, and contact OR directly for related questions in the future.

2. Update SDS in time. After REACH registration is completed, SDS needs to be updated. REACH registration number is added to SDS and passed to customers. REACH registration number is a string of Arabic numerals starting from 01. Enterprises can check the authenticity of registration number on EU REACH official website. In addition, if the registered substance has a hazard classification and the registered tonnage exceeds 10 tons/year, the SDS should be followed by an exposure scenario section for the use of the substance.

3. Continue to pay attention to the use of the product. The use of the product purchased by the customer should be included in the registration file and cannot be changed at will. For example, if the intermediate registration is selected during registration, the product is limited to the intermediate use and cannot be used for other purposes.

4. Substances of concern enter CoRAP (EU Rolling Bar Program). The EU will regularly evaluate substances that may be harmful to human health or the environment, and make discrimination through subsequent provision of additional data and exposure. Therefore, registrants need to pay additional fees for testing. Once substances are added to the authorized list due to high risks, the later export business will be greatly affected, so special attention is needed.

5. Fulfill SVHC notification or authorization obligations. If the REACH registered product is classified as SVHC (substance of high concern) and the content in the product is greater than 1% and the export volume is greater than 1 ton/year, then the enterprise needs to notify downstream users to transmit SVHC information.

Q: How to use REACH registration number to complete trade?
As we mentioned earlier, after completing the REACH registration, the registrant will get a set of digital numbers, the REACH registration number, so how to complete the trade through this registration number?

1. For direct export by the registrant, it is relatively simple. You can directly send the registration number to the customer (note: the last four numbers may not be provided) to prove that you have completed the registration and the trade can be completed.

2. For exports through agency companies, the situation is slightly more complicated. The registrant needs to notify OR to issue a tonnage coverage certificate to the agency company. The agency company can complete the trade by obtaining the tonnage coverage certificate.

3. It should be noted that the EU REACH registration number is a necessary condition for enterprises to open the EU market, with high gold content. Some exporters forge the REACH registration certificate and disrupt the market order. Therefore, registrants should protect their REACH registration certificate and registration number, and do not send the certificate to peer enterprises at will to prevent unnecessary trouble.

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