Contract Manufacturer Obligations under EU REACH

Question Posed:

What are the obligations of a Contract Manufacturer and OEM under the REACH regulation? I am working with a contract manufacturer who are claiming that they are not responsible for providing information. How can I respond to this?

Answer Provided:

Identifying whether the supplier in question is an OEM or contract manufacturer is the first step. If they are an OEM, your company might benefit from the following example:

Article 33 of REACH places an obligation on manufacturers of products to provide enough information to allow the safe use of the article to the recipients of the article. In this case, recipients are industrial or professional users and distributors. As a minimum the name of the substance in question has to be communicated.  As a professional user, [organization name] is entitled to receive this information proactively and without charge.

Refer to the following link for details: https://echa.europa.eu/regulations/reach/candidate-list-substances-in-articles/communication-in-the-supply-chain.

If the supplier in question is a contract manufacturer, your company might benefit from the following example:

Thank you for your follow-up.  Article 33 of REACH places an obligation on manufacturers of products to provide enough information to allow the safe use of the article to the recipients of the article. In this case, recipients are industrial or professional users and distributors. As a minimum the name of the substance in question has to be communicated.  As a professional user, [requester name] is entitled to receive this information proactively and without charge.

Refer to the following link for details:

https://echa.europa.eu/regulations/reach/candidate-list-substances-in-articles/communication-in-the-supply-chain.

If you are claiming [requester name] has full or partial control over the BoM and supplier selection, please send [requester name] a Certificate of Compliance any of the parts, processing chemicals, and any solders or other materials that you have selected and a reference to the BoM and your quotation, so we might close the loop on any communication disconnects.

Reference: https://echa.europa.eu/regulations/reach/candidate-list-substances-in-articles/communication-in-the-supply-chain.

**Article contents valid as of 2018-06-23

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