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REACH Roles

Almost every business in the UK will have a new responsibility under REACH. There are three main types of REACH dutyholder, which are explained below - you may also wish to look at the navigat or tool provided by the European Chemicals Agency (ECHA) to see how you fit in.

Manufacturers/Importers

Businesses that manufacture or import (from outside the EU) 1 tonne or more of any given substance each year are responsible for 'registering' that substance with the European Chemicals Agency. Registration involves submitting a dossier of information about the substance and its uses, etc. Because substances in articles also count (if these substances are intended to be released during use), it's possible that some manufacturers/importers of such articles will be registrants.

The registrant directs downstream users in the appropriate risk management measures for any particular use of the substance and responds to other actors on other aspects of REACH. Registrants of phase-in substances should have pre-registered them between 1st June and 30th November 2008 to benefit from the phased registration deadlines. Late pre-registration is now only available to first time importers/manufacturers.

You may find the following information useful:

Downstream users

Downstream users include any business using chemicals, which probably includes most businesses in some way. Companies that use chemicals have a duty to use them in a safe way, and according to the information on risk management measures that should be passed down the supply chain. There is also an opportunity to pass information about use back to registrants so that this can be taken account of when assessing the risks of chemical used.

Downstream users may need to supply risk assessment and risk management measures to the European Chemicals Agency if they don't want their supplier to know about how they use the chemicals. Some users may also be importers and have a duty to register.

You may find the following information useful:

Other actors in the supply chain (i.e. distributors, suppliers)

Businesses that sell chemicals have specific duties to pass information down to their customers, and also to pass information back to their own suppliers when customers ask them to do so. For more information look at the overview for actors in REACH on the ECHA page.

Updated 2016-09-07