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Reichhold REACH
Frequently Asked Questions

What is REACH?
REACH is a new European chemical regulation that aims to improve protection of human health and the environment from the risks of chemicals while enhancing the competitiveness of the European chemical industry. REACH replaces over 40 pieces of prior chemical legislation and creates a single system for the registration, evaluation, authorization, and restriction of chemicals in Europe.

Why should I be concerned about REACH?
REACH is very wide in scope and affects nearly all companies manufacturing, importing, or using chemicals in the European Union as well as the European Economic Area (Norway, Iceland, and Liechtenstein). REACH covers all substances whether manufactured, imported, used as intermediates, or placed on the market, either on their own, in preparations (mixtures), or in articles unless they are specifically exempted.

I don't export chemicals to Europe. Do I need to be concerned about REACH?
In most cases, no. Non-EU companies do not have any direct obligations under REACH. If, however, you import chemicals from Europe, you should contact your suppliers to make sure they are aware of REACH, understand their obligations and more importantly, plan to continue to manufacture the chemicals you purchase from them. Also, if any of your non-EU customers export their products into the EU, they will be impacted by REACH, which may impact you.

I am a downstream user of chemicals in Europe. Do I need to do anything?
REACH requires communication up and down the supply chain. Downstream users must communicate with their suppliers regarding the applications or intended uses of a certain product. Suppliers must provide their customers with information on hazards and safe conditions of use. Downstream users must ordinarily follow the supplier's advice on measures to control risks as provided in safety data sheets and any attached exposure scenarios. Downstream users should also ordinarily contact their supplier if their use is not covered by an exposure scenario; if they discover new information on the hazards of the product; or if they believe the risk management measures provided are not appropriate.

Further information on downstream user obligations can be found by using the REACH Navigator tool http://guidance.echa.europa.eu/

I am a distributor of Reichhold products in Europe. Do I have any obligations under REACH?
Under REACH, the term "distributor" is defined as any natural or legal person established within the EU who only stores and places on the market a substance, on its own or in a preparation for third parties. The REACH regulation states that this would include a retailer, and ECHA has taken the position that it also includes re-branders and storage providers. If a party otherwise meeting the definition of a "distributor" makes any use of a product containing a substance covered under REACH (such as repackaging such product purchased in bulk into smaller containers), that party automatically loses its regulatory status as a "distributor" and becomes a "downstream user" under REACH.

The main obligations of distributors under REACH are to pass information up and down the supply chain. Retailers, re-branders, and storage providers are considered by ECHA to meet the REACH definition of "distributor" and would therefore have the same obligations as distributors. Specific information on distributor obligations can be found by using the REACH Navigator tool http://guidance.echa.europa.eu/.

Also keep in mind that distributors who import Reichhold products will lose their REACH status as "distributors" be subject to the REACH requirements applicable to importers, unless they have made arrangements with Reichhold's REACH coordinators to have the substances in such products covered by the pre-registrations/registrations of Reichhold's Only Representative in which case they may be regarded as downstream users.

I would like to export Reichhold products or formulations containing Reichhold products to Europe. What do I need to do?
Reichhold, Inc., Reichhold do Brasil Ltda., and Reichhold Quimica de Mexico, S.A. de C.V. have appointed Reichhold UK Ltd. as their Only Representative (OR) to pre-register substances comprising selected products they manufacture outside the EU. To benefit from Reichhold's OR appointment, you must contact Reichhold's REACH coordinator (Victoria.sayer@reichhold.com) to discuss your specific situation (i.e., products involved, annual quantities, importers, etc.) and reach agreement on respective obligations.

Please note that pre-registration is not a commitment to registration. Business decisions to register substances will be made in the future as more information becomes available.

These materials have been prepared for informational purposes only and are not legal advice. This information is to the best of our knowledge based on accurate and reliable information, but may be subject to revision as new information becomes available. However, no representation, warranty or guarantee is made as to its accuracy, reliability or completeness. You should consult with your own counsel as to the suitability of such information for your own particular situation.

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