Obligations to Past Customers

Question: I have a customer that has not purchased materials from us since 2013. Am I required to provide them with a declaration or response for EU REACH, EU RoHS and/or the Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65)? 

Answer: If the contract or original purchase agreement addressed the need to provide data for a certain period of time, failure to provide data may reduce the potential for future business.

However, the obligation to provide information is purely based on a business to business relationship. If there is no defined contractual or regulatory requirement for information to be provided, then it’s up to the company to re-engage if they require additional declarations or responses. 

This information is accurate as of July 5, 2019.

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