REACH Legislation - What do companies that buy chemicals need to do?

[Former Member]

I currently work in the IT team for a company that is investigating the impact of the Reach Legislation and what steps need to be taken to comply. The confusion we are experiencing is that we do not manufacture or import chemicals but use them in subsequent manufacturing processes. The keys areas that I would like your feedback and thoughts on are:

1. Are buyers of chemicals liable if they buy from a supplier that does not register? Will there be penalties enforced on companies such as ours?

2. If a supplier fails to register and this impacts the supply chain in term of source of supply, are people actively monitoring their suppliers to make sure they register? If a deadline date is approaching and the supplier does not register it should flag to procurement that they will need to start negotiating a contract with an alternative supplier. So using SAP to store registration information that can be reported on by procurement... A hurdle we are already experiencing is that a supplier does not HAVE to provide this information to their customer.

We have looking at the Reach compliance workbench provided by SAP but feel that we are not the intended target customer for such a product. However, I am keen to understand whether it can still help a company like our or whether there are areas other companies are investigating.

Many Thanks, Matt

[Former Member]

Hello Matt.

Really interesting and thought provoking. I have the following to say.

1) Article 5 applies to all the Supply Chain Actors.

Though it mentioned that manufacturers, the guidance of ECHA specifies that downstream user cannot "USE" or place on market substances which requires pre(registration).

Authorities may enforce action against any actor in the supply chain who violates the requirement.

2) ECHA recommends to make inventory of the substances being used and identify againist those already pre-registered to ensure smooth business operations.

I aggree with that idea of some integration with Procurement for parking the registration information for alternative supplier.

In REACh, using Dashboards, Registration statuses / U&E information is monitored and using emails and escalations we can trigger email notifications. Such emails can also be routed to Procurement to see for alternative suppliers. However, as you envisioned, it may not be possible - parking the data for want of alternative supplier. Again in a Supply chain, how many such escalations needed that also needs to be discussed for some sort of tight integration with Procurement division.

Thanks

Jayakumar