Articles 33(1), 33(2) and 7(2) of REACh place communication and notification duties onto “downstream users” of chemicals (i.e. all manufacturing businesses). Your commercial customers must be informed about the composition of the products you supply them, and members of the public have the right to demand information about certain substances contained in your products. This has been a legal duty since 2009 and it is a criminal offence to make a false statement.
The requirements are that you;
1. Identify any Substances of Very High Concern (SVHCs published in the “Candidate List”, which is updated twice annually) that are present in your finished product whether it’s a paper clip or a laptop computer, then
2. Determine if the SVHCs are present at greater than 0.1% w/w concentration in your finished product. If they are you must provide details to your commercial customer the first time that product is supplied to them, after any of the substances in the product appear on the Candidate List for the first time. You must also supply the same information to any members of the public that request the information within 45 days even if the consumer did not buy the product directly from you.
3. If the 0.1% w/w threshold is exceeded and you supply more than a tonne of any SVHC contained in all your products you must notify the European Chemicals Agency (ECHA).
These requirements apply to any product sold into the European Union and so the requirements will remain after ‘Brexit’.
The ParaChem ReachWARE Tool enables you to produce all the necessary data to comply with the three items above. Click here for a demonstration.
For more information on how ParaChem can help you and your business, please Contact us.