1. Does injection molded product manufacturers directly export to the EU have anything to do with REACH?
In this regard, it is necessary to consider notification of substances of very high concern, control of restricted substances in products, information transmission within the supply chain, etc.
2. Are polyethylene films, direct exporters related to REACH?
Same as above
3. Who should be informed?
Notify to the European Chemicals Agency, ECHA.
4． What if I make a mistake in judgment?
Misjudgment will bring huge losses to the company. For example, products cannot enter the EU and are subject to huge fines by EU member states. You may consider asking professional organizations to assist you.
5. If there are substances of very high concern after testing, should EU customers be required to notify them and when should they be notified?
When the presence of substances of very high concern is detected, ECHA must be notified when the following four conditions are met:
- Concentration>0.1%n
- Export volume n>1t/a
- Not registered n
- Exposure n cannot be ruled out
6. If registration is not required, what do we need to do?
If you need to consider risks such as notification of substances of very high concern, control of restricted substances in products, information transmission within the supply chain, supply chain interruption, etc. To carry out these tasks, you need to know the ingredients, ask the supplier to provide or third-party testing, and the customer will follow up You may be provided.
7． What does the exporter of electronic items, not intentionally released, need to do if the manufacturing ingredients are on the list but not directly to the EU?
Risks such as notification of substances of very high concern, control of restricted substances in products, information transfer within the supply chain, and supply chain interruptions need to be considered.
8. What if it is in the authorization list?
Depending on the product type, supply chain level, role within the supply chain, customer requirements, etc., it may be necessary to consider applying for authorization, reporting substances of high concern, etc.
9. How does EU customs manage whether goods can be exported or not?
After obtaining authorization, an authorization number must be affixed to the product. After successful pre-registration, there will be a pre-registration number, and after successful registration, there will be a registration number, which can be viewed by the customs.
10. Polyethylene film is exported directly. Customers have requirements. In what format?
If the customer has requirements, there may also be format requirements, so just follow the customer's format; if the customer does not
If the format is provided but specific requirements are made, then the industry will have a common format and you can contact professional organizations.
11. Will it be required to provide raw materials and additive ratios?
It depends on what requirements of REACH need to be met. For example, when registration is required, information on substances exported in products exceeding one ton needs to be provided, regardless of whether the substance is a raw material or an additive (as long as it is not used as a product stabilizer).
12. If the information is provided to the customer first and then to the EU, will the information be leaked?
There is a possibility of leakage, so you can find the only representative, who has the obligation to keep confidential.
