1. Does the direct export of injection molded parts to the EU by manufacturers relate to REACH?
This includes considerations such as the notification of substances of very high concern, the control of restricted substances in products, and information transmission within the supply chain.
2. For polyethylene film, are direct exporters related to REACH?
Same as above
3. To whom should we notify?
Notify the European Chemicals Agency (ECHA).
4. What if I make a wrong judgment?
A misjudgment could result in significant losses for the company, such as products being barred from entering the EU or imposing hefty fines from EU member states. Consider seeking assistance from a professional organization to address these issues.
5. Assuming the test reveals substances of very high concern, should the EU customer be notified, and if so, when?
When a substance of very high concern is detected, ECHA must be notified if the following four conditions are met:
- Concentration > 0.1%
- Export volume n>1t/a
- Unregistered n
- Exposure cannot be ruled out.
6. If registration is not required, what do we need to do?
To address risks such as notification of substances of very high concern, control of restricted substances in products, information transmission within the supply chain, and supply chain disruptions, it is necessary to know the composition of the substances. This information can be obtained from suppliers or third-party testing, and customers may request it from you later.
7. Electronic articles, without intentional release, if the manufacturing ingredients are on the list but not directly exported by the EU, what needs to be done?
Risks such as notification of substances of high concern, control of restricted substances in products, information transmission within the supply chain, and supply chain disruptions need to be considered.
8. What if it's on the authorization list?
Depending on the product type, supply chain level, role within the supply chain, and customer requirements, it may be necessary to consider applying for authorization or notifying customers of substances of very high concern.
9. How does EU customs manage whether or not exports are permitted?
After authorization, an authorization number must be affixed to the product. A pre-registration number is issued upon successful pre-registration, and a registration number is issued upon successful registration; these can be verified by customs.
10. For direct export of polyethylene film, what format does the customer require?
If the client has specific requirements, they may also have formatting requirements; in that case, just follow their format. If the client does not...
If a format is provided but specific requirements are specified, then there will be a common format in the industry, and you can contact a professional organization.
11. Will you be required to provide the ratio of raw materials and additives?
It depends on which REACH requirements need to be met. For example, if registration is required, information on substances that are exported in quantities exceeding one ton in the product needs to be provided, regardless of whether such substances are raw materials or additives (as long as they are not used as product stabilizers).
12. If information is provided to customers first and then to the EU, will the information be leaked?
There is a possibility of leakage, so a sole representative can be found, who has an obligation to maintain confidentiality.
