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REACH and SMEs Will you be affected?

REACH and SMEs Will you be affected?. How will you be affected by REACH?. As manufacturer / importer of substances / preparations Registration As producer / importer of articles Registration, notification and information flow As retailers Information flow. Will you be affected by REACH?.

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REACH and SMEs Will you be affected?

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  1. REACH and SMEsWill you be affected?

  2. How will you be affected by REACH? • As manufacturer / importer of substances / preparations • Registration • As producer / importer of articles • Registration, notification and information flow • As retailers • Information flow

  3. Will you be affected by REACH? • Do you manufacture / import substances / preparations? • NO • nothing more to do • YES • see next slide

  4. Will you be affected by REACH? • Do you manufacture/import substances / preparations in quantities above 1 tonne per year? • NO • nothing more to do • YES • see next slide

  5. Will you be affected by REACH? • Manufacturer / Importer has to register: • the substance if manufactured / imported on its own • all the substances present in the preparation

  6. Will you be affected by REACH? • Do you produce / import articles? • NO • No registration or notification • YES • see next slide

  7. Will you be affected by REACH? • Regarding articles • 2 possibilities

  8. Will you be affected by REACH? • 1st possibility • Do the articles produced or imported contain substances: • in quantities above 1 tonne per year • intended to be released?

  9. Will you be affected by REACH? • If and only if YES to both questions • REGISTRATION for that substance is required • If NO to one of the two or the two questions then • NO REGISTRATION

  10. What is Registration? • Registration of substances / preparations /articles consists of: • Technical dossier • Chemical Safety Report (exemption for < 10 tonnes) • Pre-registration between 1 June 2008 and 1 December 2008

  11. Will you be affected by REACH? • 2nd possibility • Does the article contain a substance of very high concern • in quantities above 1 tonne per year? • is the substance present in a concentration above 0.1% weight by weight?

  12. Will you be affected by REACH? • If and only if YES to both questions • NOTIFICATION for that substance is required • If NO to either one of the two or the two questions then • NO NOTIFICATION

  13. What is notification? • Some of the information required under the notification procedure • Identity of the producer or importer • Identity of the substance • Classification of the substance • Description of the use fo the substance in the article

  14. Will you be affected by REACH? • All retailers selling articles will be affected by consumer information obligations

  15. What are consumer information obligations? • Consumers can ask their retailer if an article contains substances of very high concern. The retailer will have 45 days to respond. • Problem: the retailer might not have this information

  16. Where to get help • Agency helpdesk • National helpdesks • Industry helpdesks • Guidance documents • RIP 3.8 • Upcoming EuroCommerce guidelines

  17. Example of what EuroCommerce guidelines might contain • How retailers can prepare • List all productsaccording to manufacturer / importer • Prioritization of the internal implementation tasks according to the time sequence of obligations • Information gatheringfrom suppliers and/or conducting own analyses

  18. Example of what EuroCommerce guidelines might contain • How retailers can prepare • Pre-registration: • Preparation of a list of all relevant articles with intended release; • Calculate tonnage thresholds for all substances in relevant article group • Information: • Prepare as for in notification; manage data

  19. Example of what EuroCommerce guidelines might contain • How retailers can prepare • Notification: • Cluster articles in categories and identify potential, relevant substances, • calculate tonnage thresholds for all substances in relevant article group; • check against existing substance prohibitions (azo dyes in textiles, heavy metals in electrical appliances, etc.) • Registration: Communication with potential consortium partners

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