REACH knowledge base – The obligations of distributors in the REACH communication
REACH distinguishes the information range which should be forwarded “downstream” or “upwards” in the supply chain.
The information is forwarded downstream to the end user from the manufacturer (as the primary data owner), possibly through one or more distributors (mainly in the form of a safety data sheet).
At the same time the registrant needs certain data from the users of the substance/mixture (e.g. identified uses, technologies used during use, etc.), to be able to prepare the exposure scenarios for the identified uses as part of the chemical safety assessment.
It should be noted that a wider range of data and information change is needed – than the above – to enable all members of the supply chain to fulfill their tasks properly.
*A user can also purchase a product in a retail outlet, but regardless the obligations of the distributor do not change (e.g. a safety data sheet should be provided if applicable)!
Data, information to be supplied toward the end user in the supply chain
In practice, such a statement is not always sent by the registrants, so it may be worthwhile to initiate proactively and make such a request to the supplier.
This circle shall include, where appropriate, the transfer of the safety data sheets extended by exposure scenarios (eSDSs) and supplying the registration number either in the safety data sheet or, if no safety data sheet is required for the substance or mixture, then otherwise (when the REACH registration will be completed by the appropriate deadline if the manufacturer/importer is obliged to do so).
Communicating identified uses:
If a safety data sheet is required for the substance, then after the registration of the substance the relevant information on the registered uses will be communicated to all members of the supply chain in the safety data sheet. This also means that it is advisable to disclose information about our identified use to the manufacturer of the substance until the registration deadlines, this way we will be able to get a safety data sheet that contains relevant information for us too. In this process, the distributor has a data mediator role, and may draw their customers attention to these advantages.
Providing information for suppliers on new hazard information:
Customers of the distributors (i.e. downstream users) may include companies that have data on the hazardous properties of the substance.
Therefore, in the interpretation of the regulation, all data should be considered as “new”, that the supplier has not communicated earlier toward the downstream users and which is not available in public databases or in literature (e.g. observations on acute human health effects at workplace).
All members of the supply chain, along with the distributor, who receive such information from the buyers, must pass the information upstream to the next member in the supply chain.
(Data, information not necessary to be disclosed by the members of the supply chain)
(1) Identified uses can also be specified by using SU codes (sector of use)
(2) According to the quantitaty ranges presented in the “registration deadlines”, it is sufficient to provide the annual quantities manufactured/imported.
REACH excludes some of the materials used in articles from its scope, so there is no REACH procedure for these:
There is no need to apply the directions on registration and on evaluation, restriction and information forwarding in the supply chain:
There is no need to apply the directions on information forwarding in the supply chain:
For more information on exemptions, see REACH Article 2.