As an EU enterprise, if you have not started any REACH preparations it is strongly recommended that you give the highest business priority to the following 5 steps:
- Make a comprehensive inventory of all substances at 1tpa and above (on their own, in preparations or in articles) involved in your business
- For each substance,
- determine if you are the manufacturer, importer, downstream user or maybe a
combination of these roles in the supply chain
- detail the tonnage per annum (a three year average is acceptable)
- list the EINESC or CAS number - Identify high tonnage substances as well as critical or vulnerable substances in your business and focus on how these will be handled under REACH
- Aim to pre-register each substance in 2008 (to gain time and to continue handling these substances after 2008)
- Where you are a user of substances, understand your supplier’s REACH intentions to guarantee continuity of supply and ensure your supply chain will register your particular use
For a manufacturer based outside the EU, begin to understand how your supply chain (your EU-based importer) is preparing for REACH; the pre-registration stage in particular.
If appropriate consider appointing an EU-based only representative to fulfil your substances’ REACH obligations.