How do I know if a supplier has registered a substance and/or if the substance has already been registered by someone else?
The REACH Registration list is located here: https://echa.europa.eu/information-on-chemicals/registered-substances. It is a searchable database that will help determine if a substance has been registered.
If you are a direct manufacturer and/or importer of a substance or mixture made up of one or more substances and you are importing over 1 ton of that substance, you are required to register. If you are a downstream user of a substance, you are probably not required to register. You should however confirm that the substance you are using is registered for your specific use using the registration database link above. You can use ECHA Navigator to help you determine if you need to register your specific substance: https://echa.europa.eu/support/guidance-on-reach-and-clp-implementation/identify-your-obligations/navigator/-/navigator/obligation/0206-4920-8902/5
Examples of when registration is needed:
- A manufacturer of a substance who uses the manufactured substance himself has a duty to register each substance manufactured in quantities of 1 tonne or more per year, unless exemptions apply, and will have to include information on his own use(s) and any identified uses of his customers in his registration.
- An importer of a mixture has to register those substances which are present in the imported mixture in quantities of 1 tonne or more per year, unless exemptions apply. He will have to include information in his registration on the identified use(s) of the substance(s) in the mixture. There is no obligation for importers of mixtures to register the mixtures as such; indeed mixtures cannot be registered.
Examples of when registration is not needed:
- Any user of substances not manufactured or imported by himself, is a downstream user and has no obligation to register these substances.
- An importer of a substance, a mixture or an article, who is importing from a non-EU company who has appointed an ‘only representative’ will be considered as a downstream user and therefore does not need to register. The non-EU company needs to inform the importer of the appointment. In addition, the only representative should have an up-to-date information on the importer’s identity and quantity of imported substance.
- A manufacturer or importer of a substance which is exempted from registration under REACH has no obligation to register that substance.
Reference 1 (REACH Registration List):https://echa.europa.eu/information-on-chemicals/registered-substances
Reference 3 (Registration Guidance): https://echa.europa.eu/documents/10162/23036412/registration_en.pdf/de54853d-e19e-4528-9b34-8680944372f2
**Article contents valid as of 2017-06-01