Non-EU formulators (producers of ‘mixtures’) may purchase substances that have already been registered by their non-EU supplier. Or they may buy substances that were registered by their European Manufacturer. Where this is the case, the importer or the non-EU formulator’s Only representative no longer needs to register the substances.
In practice it is very difficult to obtain adequate proof of such REACH Registrations. A simple letter giving the registration number and the tonnage band could be enough. But the registrants sometimes require signatures under complicated contracts, wish their own OR to have the contact details of all the formulator’s European customers and sometimes even regard their registration numbers as confidential business information. Lack of guidance and lack of knowledge of REACH makes for many different perceived problems and as many different solutions.
Paul W.Verspoor MBA
Sitmae REACH Services BV
PB 1644, 3600 BP Maarssen, The Netherlands