Case studies

These case studies are designed to help stakeholders understand how they might fit into REACH. They reflect the experience of the types of questions asked of the CA helpdesk. The CA recognises that these case studies are idealised and will not necessarily reflect the potentially more complex environment in which many businesses operate. However, they have been designed to provide simple guides to common situations.

The CA welcomes, therefore, any suggestions for improvements: any comments should be submitted on via the email account. The CA will be adding further case studies over the coming months and welcome suggestions for other scenarios. In addition, the CA would be pleased to work with any stakeholders to develop other scenarios which may be of interest to a wider audience. 

1. Downstream user with confidential uses
   A medium sized company supplying preparations to the marine sector consider the implications of choosing to keep this use of a substance confidential from their suppliers and what further action they may need to follow as a downstream user under REACH.
2. Small company has registration duties under REACH
   A small company making plastic piping looks at the substances they use in their manufacturing processes and decide to continue import from outside the EU accepting the registration duties that this brings.
3. Small company is reassured over continuity of supply
   A small company making sealing products determines that they are downstream users and ensures that the supplies of substances will be secure under REACH, including one which is not usually used for making these types of materials.
4. Non-EU company appoints an only representative
   A non-EU chemical manufacturer that exports to a range of customers in the EU decides to appoint an Only Representative to undertake the REACH obligations associated with the imports making the EU-based importers downstream users.
5. Alloy producer clarifies duties under REACH and is able to reassure customers of future supply
   A producer of alloys determines that under REACH it is the component metals that constitute the alloys they manufacture that are within the scope of registration and for one of these that they import they will have registration obligations.
6. UK chemical manufacturer resolves issues on intermediates under REACH
   A chemical company that manufactures two intermediates, one used on site and one exported to a sister site in another EU country, determines the REACH requirements for these substances. 
7. A small company importing a solvent from the US is daunted by REACH
   A small company importing a solvent for the first time from outside the EU is concerned about having missed the pre-registration deadline but finds they can pre-register and get help from other SIEF members.
8. Self-employed painter and decorator learns about REACH
   A self-employed painter and decorator using products routinely as specified by the supplier is relieved to discover that he will still be able to get the products he needs and will have little to do under REACH that he is not already doing to meet his health and safety obligations.
9. Pharmaceutical manufacturer learns about how REACH applies to his business
   A company producing medicines clarify that the ingredients (both active and non-active) of their final products are exempt from most aspects of REACH.
10. Company producing biocidal and plant protection products clarifies their status under REACH
    A company producing biocidal and plant protection products determine that their active substances are already considered as registered under REACH because they are within the PPPD or BPD systems.  However, they may need to participate in substance information exchange fora (SIEFs) and share any animal test data they hold with those companies that need to register the same substances for other uses.
11. UK Steel processing company clarifies position of steel as articles
    A UK steel processing company that manufactures 'merchant bar' from steel 'billet' contacts trade associations to clarify the position with semi-finished steel products in REACH.  They find that many of the materials they deal with can be considered articles.