Welcome to the REACH Manganese Consortium - a voluntary organisation with the sole aim to support its members in working jointly to comply with REACH obligations in a timely and cost effective way. How are you preparing for REACH?
If you are an EUEuropean Union -based manufacturerManufacturer: means any natural or legal person established within the Community who manufactures a substance within the Community; or importerImporter: means any natural or legal person established within the Community who is responsible for import; and you have not developed a REACH strategy it is recommended that you prioritise the following 6 key steps:
- Appoint a REACH 'champion' or specialist in your organisation.
- Make a list of all substancesSubstances which occur in nature: means a naturally occurring substance as such, unprocessed or processed only by manual, mechanical or gravitational means, by dissolution in water, by flotation, by extraction with water, by steam distillation or by heating solely to remove water, or which is extracted from air by any means; (on their own, in preparations or in articles) involved in your business at ≥1mt per year.
- For each of these substances,
- detail your role: manufacturerManufacturer: means any natural or legal person established within the Community who manufactures a substance within the Community;, importerImporter: means any natural or legal person established within the Community who is responsible for import;, downstream userDownstream user: means 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. A re-importer exempted pursuant to Article 2(7)(c) shall be regarded as a downstream user; in the supply chain
- detail the substance tonnage per annum
- list identification numbers e.g. EINECSEuropean Inventory of Existing Commercial Chemical Substances (EINECS) or CAS. - Identify any substances that are critical to your business and focus on how these will be handled under REACH.
- Plan how and who will pre-register each substance before 30 November this year.
- Understand your key supplier’s REACH plans to ensure that those supplies will continue uninterrupted from the end of 2008.
If you are a substance manufacturer based outside the EU, you should question and understand how your EU-based importer is preparing for REACH. You may decide to appoint an EU-based REACH Only Representative to fulfil the obligations that would normally fall to your importer/s. Whatever your plans, ensure that your importer or Only Representative aims to pre-register this year in order that your supplies to the EU can continue from December 2008.
NB: PRE-REGISTRATION OF PHASE-IN SUBSTANCES IS UNDERWAY, ENDING ON 30 NOVEMBER THIS YEAR
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Last update: October 2008 |
