Perfect Piping, a small company based in Staffordshire, makes plastic piping for a range of uses from industrial through to domestic. The company forms pipes in processes using various chemicals which are bought in from a number of different locations.
The managing director, became aware of the REACH Regulation which she thought might apply to her business. On discussing this with her trade association and looking on the internet she found a number of different sources of information on REACH and decided that it does apply to her company. She read that the duties of a company under REACH vary according to where any particular chemical, possessed, marketed and /or used by the company has originated from. She also read that a good starting point is to make an inventory of all the chemicals of interest to the company.
Sandra, in consultation with her company chemist made a list of all the chemicals her company uses, who supplies them, and which are the most important to the business. In doing this, Sandra became uncertain about where her company fits in under REACH as she realised that many of the ingredients she buys come from outside the UK and isn’t sure if she is an “importer” with registration duties. She decided to seek out more help and approached the UK REACH Competent Authority helpdesk for some advice.
On speaking to the helpdesk staff, Sandra confirmed that, as Perfect Piping buys nearly all of their ingredients from somewhere else in the EU (Germany, Slovakia and Poland) then they are in fact a Downstream User for all of these chemicals. As such Sandra wanted to be sure that these uses will be covered in the registrations that will be made by the manufacturers who will register them. Sandra identified that, as these ingredients are used in ways that the supplier intends, it is likely that these uses will be supported, but she still decided to check this with her suppliers.
However, one of the ingredients key to her business is supplied from the USA and as such Perfect Piping are considered the Importer under REACH. As Perfect Piping buy in around 2 tonnes per year they will have registration duties for this substance. After careful consideration of the options open to her, Sandra decided that she will continue to import this substance and therefore will need to register it. She again spoke to the helpdesk and they explained the registration duties particularly emphasising the importance of pre-registration. They explained that if Perfect Piping pre-register the substance between 1st June and 1st December 2008, because they only import 2 tonnes per year, they would not need to complete a full registration until 2018. Helpdesk staff also explained that pre-registration might enable her to take part in the sharing of data if other companies have also pre-registered this substance. Sandra subsequently signed up her company for REACH-IT and pre-registered the substance. Her company will now be able to continue to import it and decide if they wish to continue to import after 2018, in which case they will need to fully register.
