The extent to which you are affected by the REACH Regulation depends on what you do. For example, it makes a considerable difference whether your company purchases its products only from suppliers in the European Economic Area (28 EU countries plus Norway, Iceland, and Liechtenstein) or imports them from elsewhere.
It is also important to consider whether your products are substances, mixtures, or articles. There are also borderline cases in which clarification is not always easy.
Is your substance an intermediate in the synthesis of another substance? Does a chemical reaction take place on your company’s premises at all? Or do you mix a formulation based on customer requirements?
Are the substances that you handle hazardous? Are they combustible or can they affect the health of workers, consumers, or the environment?
Depending on how you answer, you may have to fulfil certain obligations. The more hazardous the substance, the more obligations you must fulfil. Moreover, the regulations have various exceptions that are not always easy to interpret.
Everything begins with a concern analysis. Probably that’s even how you began – first understanding the regulations, then figuring out what to do, and finally implementing the obligations. Done.
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