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REACH—The Essential Guide

Posted: June 16, 2008

page 5 of 6

Implications for the Supply Chain

The impact of REACH will be felt throughout the supply chain. From raw material suppliers to end product manufacturers, everyone will be affected by the new regulation. Suppliers in the EU, for example, will now be assessed differently to those outside the EU who have no registration obligations. Suppliers outside the EU cannot register for REACH directly. They can, however, opt to nominate an ‘only representative’—an EU-based representative of a non-EU manufacturer. Appointing an ‘only representative’ allows manufacturers to participate in the REACH process and ensures that they will be able to market their product directly in the EU. It also has advantages for EU importers. They are spared the task of registering the product under REACH and will be regarded as a downstream user. 

Throughout the REACH process, customer needs should remain paramount. To maintain optimum customer service, Treatt, for example, has appointed a dedicated coordinator for REACH-related matters to respond to all customer and supplier queries. This contact is an in-house expert on the regulations, providing support to the technical, sales and purchasing teams on REACH-related matters, and assisting senior management in developing a company action plan.

The Three Cs

Those affected by REACH should consider the three Cs when implementing an action plan: communication, confidentiality and costs.