Who is affected by REACH? (considering Articles / Products)
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Who is affected by REACH?
In principle, REACH applies to all chemical substances: not only those used in industrial processes but also in our day-to-day live; for example, in cleaning products, paints, and articles such as clothes, furniture and electrical appliances. Therefore, REACH impacts on a wide range of companies across many sectors.
What a company must do to comply with REACH will depend on its role in the supply chain. In general, under REACH you may have one or even multiple roles:
- Manufacturer and importer: A manufacturer under REACH is any company that manufactures a chemical substance within the EU, while an importer is any company that imports a chemical substance from outside the EU. These actors are considered to have most of the responsibilities relating to the chemical they introduce into the EU market.
- Downstream user: Any natural or legal person established within the EU, other than the manufacturer or the importer, who uses a substance, either on its own or in a mixture, in the course of their industrial or professional activities.
- Distributor: Any natural or legal person established within the EU, including retailers, who only stores and places on the market a substance, on its own or in a mixture, for third parties.
- Producer of an article: Any natural or legal person who makes or assembles an article within the EU. Companies producing, importing and/or supplying articles will have to decide if they have to fulfil registration (Article 7(1), communication (Article 22) and/or notification (Article 7(2)) requirements related to substances in articles. Other REACH provisions may also apply to certain substances in articles, e.g. authorisation and restriction requirements.