With the deadline of June 1 2018 fast approaching, we are seeing an increasing number of foreign suppliers contacting us about our REACH Only Representation (REACH OR) service.
The first question we always get is, “Do I even need a REACH Only Representative?”
The answer as you may have guessed is always “It depends”. Although, To answer this question more completely, we often turn the conversation around. By asking these foreign suppliers the following questions?
- Are the products you import into Europe considered substances under the REACH directive?
- What are the types of products you import into Europe?
- What quantities of these products do you import into Europe?
- Do you have a subsidiary in Europe?
Are my products considered substances under the REACH directive?
Not all foreign suppliers produce “substances” as defined in the REACH European directive. If a material is not considered a substance, then there is no registration required under the REACH directive. So, the first question to ask then is always: “Are the products I am importing into Europe considered a substance under the REACH directive?”
Are my products exempt from the REACH directive?
Many foreign suppliers believe that their products may not be considered substances or chemicals. But, they probably think that because they are not dealing in pure commodities. Or, that their products are not raw materials. Or even that their products are exempt and therefore they do not need a REACH OR.
More often than not, if they need to ask the question, then it is likely that their products do indeed fall under the classification of a substance, and they do need a REACH Only Representative.
Therefore, If you think about nail polish, silicone, glue, epoxy and surface treatments, foreign suppliers of these products, all need to be have a REACH OR.
Most often, we get questions from foreign suppliers of pharmaceuticals, agriculture (agrochemical) and even speciality chemicals. And, all of which will require a REACH Only Representative.
CAPLINQ is a specialty chemicals, plastics and products company that specializes in making foreign companies compete on a level playing field with European suppliers. Visit caplinq.com to learn more about our REACH services including our REACH Only Representation. You can also contact us if you have further questions about whether you need REACH Only Representation.