REACH REGULATION

In this section you will learn about how CEPSA Quimica is preparing to fulfill its obligations under REACH Regulation, in order to properly register its products (our deadline, November 2010).

What you should do?

The obligations of a company under REACH depend on the exact activity carried out in relation to a specific substance, either on its own, in a preparation or in an article. Therefore, each Company should first identify its role(s) under REACH for each substance it uses in order to be in position to identify its obligations.

Identification of roles under REACH

REACH makes a distinction among the different actors in the supply chain between manufacturers, importers, downstream users and distributors (including retailers and storage providers).

A downstream user is defined in article 3(13) of REACH as “any natural or legal person established within the Community, other than the manufacturer or the importer, who uses a substance, either on its own or in a preparation, in the course of his industrial or professional activities. A distributor or a consumer is not a downstream user.” Many different types of companies can be downstream users, including formulators of preparations, industrial users, craftsmen, workshops and service providers or re-fillers.The first condition for a user to be regarded as downstream user according to REACH is to purchase substances and/or preparations from an EU supplier or from a non-EU supplier who has an “only representative”.