How Non-EU enterprise who manufacture chemical register under REACH​

• Non-EU enterprise pre-register or register their substance with the European Chemical Agency (ECHA) if the quantity of the substance exported into the EU exceeds 1 ton per year

• According to REACH regulation, only EU-based legal entities are allowed to register. Hence, non-EU enterprise have to appoint an Only Representative to submit (pre-)registrations to ECHA and inform their EU importers of the appointment of the Only Representative

• Safety Data Sheets is requested to provide according to REACH and CLP standards at the first delivery of a substance or preparation if the substances or preparations meet the criteria for classification as dangerous

• It can work if one non-EU enterprise complete the registration and share the registration number with other companies on the same supply chain.

How article supplier comply REACH​

• Registration: Article suppliers shall register substances in articles if the substances are intended to be released during normal and reasonable foreseeable conditions of use and the total amount of the substance present in the articles with intended releases exceeds 1 tone per year. For example, ink in a marker or paint in a tube needs to be registered.   
  

• Substance Identification: by testing or requesting your material suppliers to conduct test, Article suppliers shall identify possible substances of very high concern(SVHC) and restricted substances in their product.

• Communication Requirement: how about if your article present a SVHC over 0.1% (w/w) concentration? Article suppliers are obliged to inform the recipients of the article along the supply chain about the chemical name(s) and how the article can be safely used. This information is required be available within 45 days upon consumer request according to REACH regulation. The SVHC candidate list will be regularly updated from time to time.

• Notification: Notification to ECHA is required if any SVHC present in the article has a concentration above 0.1% (w/w) and the total amount of the SVHC exceeds 1 tone per annum per producer or importer.

• Authorization: Those listed SVHCs in Annex XIV of REACH will not be allowed to be used, placed on the market or imported into the EU after a date to be set unless the company is granted an authorization.