REACH: Obligations concerning substances imported from third countries

Business question

We would like to know our obligations and possible costs for the registration under REACH of the following substances imported from extra-EU countries:

• Glycin
  CAS No. 56-40-6
  Quantities imported in the last 3 years:
  • 2015 = 10 T
  • 2016 = 5 T
  • 2017 = 10 T
• Sodium tripolyphosphate (food grade)
  CAS No. 7758-29-4
  Quantities imported in the last 3 years:
  • 2015 = 0 kg
  • 2016 = 78 T
  • 2017 = 0 but we intend to import 19 T in December 2017

Further information:

• These substances are imported from Italy and sold in Italy.
• These substances have not been pre-registered by us, but they have already been registered by other companies.

Answer by the expert

All the substances you buy in the EU (Italy in the case mentioned below), must be recorded by the manufacturer at the time limit corresponding to the total tonnage produced in the EU.

If you buy these substances from an Italian manufacturer, you are « downstream user » and not a manufacturer or importer within the meaning of REACH as you mention.

In this case, it should simply be verified that:

• Your supplier has successfully registered the substances mentioned
• Your supplier has registered these substances for YOUR type of use It is your responsibility to ask for proof of this (Registration No.).

You can then go consult the ECHA website your type of use is well covered. Otherwise, you can no longer use these substances until you have registered your type of use.

In case you decide to import from a non-European country, then you must register by 01/06/2018 if you exceed 1 tonne per year. Attention the registration costs can be very high!

To deepen our analysis and to assist you in your efforts, we offer you a service ofhotline support on REACH regulation, as well as dedicated additional diagnostic and training services.