Question: My company refurbishes and repairs products and equipment for our customers and loans out replacements in the interim. Some of these loaned items come from sites or subsidiaries within the European Economic Area (EEA), while some come from outside the EEA. These loaned products or pieces of equipment are not sold within the EEA, but because they may need to be imported, would these products fall under REACH Regulation requirements? Do we need to provide documentation for these items?
Answer: Within the EEA, products or equipment loaned to companies are generally regarded as being placed on the market. As such, they would need to comply with any applicable legislation, regardless of the fact that they are being provided as a loan.
Furthermore, Article 33 of the REACH Regulation communication requirements for substances of very high concern (SVHC) would still apply. Regardless of whether a product is sold, leased or loaned within the EEA, manufacturers are required to identify the presence of SVHCs and provide safe usage information.
Article content current as of 2019-10-11.