A small enterprise based in Hull imports in excess of 100 tonnes of an organic solvent from the United States each year. It uses the solvent in the formulation of products that are sold on to the retail sector and have been dealing with the same manufacturer for many years without any problems.
The enterprise’s Business Manager, Fred, has heard of REACH from some of his bigger customers. They’ve told him that chemical importers will have a duty to compile detailed dossiers of scientific information on the substances they bring into the EU and then register them with an Agency in Finland. These customers are telling him that this will start to happen next year.
This has been a daunting prospect for Fred, because it’s something his company has not planned for. It has less than 30 staff, and he is worried that they will not have the necessary skills and knowledge to get to grips with this. Fred was thinking about appointing a consultant to work on the registration dossier for the solvent, but has been put off by the high costs involved and not knowing how to select a suitable person.
Attending a seminar on REACH organised by a regional business initiative, the Manager hears how a good many companies similar in size to his have also been daunted by the scale and complexities of REACH. During a series of presentations, the experience of one particular company caught his attention.
This company had been importing dyestuffs from China for many years and had good relations with their far-eastern suppliers. In talking through the implications of REACH with them, the Chinese had surprised this company by proposing to appoint an ‘only representative’. The speaker explained how the REACH Regulation made provision for this third party and how they could undertake registration duties that would otherwise fall on his company. The only representative would be appointed by the Chinese company to register all the high tonnage substances, including some solvents, they were exporting to Europe. The speaker also explained how this would mean many importers would be saved the task of registration themselves and that they would then be regarded as downstream users of chemicals for the purposes of REACH.
After mulling this over for a few days, Fred decided to phone the solvent manufacturer in the US to see how familiar they were with REACH. He was put in touch with a Regulatory Affairs Manager, Judy, in this large company, who had heard a little about REACH already, and was able to get across to her the ‘only representative’ concept and the advantages it offered for importers.
Now, in August 2007, the US Company has decided to appoint an only representative for the eventual registration of the organic solvent. They see this as a way of ensuring continued business in several EU countries. The only representative, a specialist company based in the North-West of England with a track record in regulatory affairs, has already been in touch with all the importers of the solvent seeking some information about the uses they put it to. Consequently, Fred and his colleagues have been reassured that everything is in hand as far as registration of chemicals for REACH is concerned.