AM I AN IMPORTER?

You are an importer if you buy a chemical product directly from a supplier based outside EU and bring it into EU to distribute or formulate.

You are an EU manufacturer if you are based in EU and you produce or extract a chemical substance. If you are an EU manufacturer, continue the test as importer.

If you are the appointed EU-based Only Representative for a non-EU supplier, continue the test as importer.

AM I A DISTRIBUTOR?

You are a distributor if you source a chemical substance or a mixture within the EU, store it and then place it on the market for someone else. For example, wholesalers and retailers are distributors.

Formulators do not manufacture substances but only mix together substances and/or mixtures from EU and supply them further down the supply chain or directly to consumers. If you are a formulator, continue the test as distributor.

Are your products labelled correctly?

As the importer, you must establish if the mixture is hazardous by applying the classification criteria set out in the CLP Regulation. Substances classified as hazardous and present in the mixture above the concentration limits, which results in the classification of the mixture as hazardous, must be notified to the Classification and Labelling inventory (ECHA).

In case of hazardous substances or mixtures you must make sure that the products are labelled and packaged in accordance with the CLP regulation to communicate the risks and ensure safe handling by your customers.

Note that the hazard labels are required to be written in the official language of the EU Member States where the substance or mixture is marketed.

This means that if you wish to sell your products in every European country, the hazard labels must be written in all 24 official languages.

Example of a CLP hazard label:

Can you provide us with EU Safety Data Sheets?

You must provide the relevant information in a Safety Data Sheet, required by the REACH regulation, to communicate the risks and ensure safe handling by your customers.

The Safety Data Sheets must be available in the respective national languages.

This means that if you wish to sell your products in Europe, the Safety Data Sheets must be written in all 24 official languages. Note that the different languages are not copied translations, they must include information required by the national legislations, for example, on health and safety or disposal of waste.

Are you aware of all legal limitations and restrictions?

You must make sure that the chemicals comply with current limitations/restrictions, if they are on the REACH Candidate List of chemical substances of very high concern or on the REACH Authorisation List. To make sure of this, you need to know the complete composition of the mixture, not only the composition of the classified substances. Several substances are not classified as hazardous but have a national occupational exposure limit (an example is propylene glycol, which so far has not been classified as dangerous, but has occupational exposure limits in several European countries).

In addition, some substances must be REACH registered if they are imported in quantities exceeding 1 tonne per year.

Do you regularly follow up on your products?

You need to be aware of any restrictions and monitor the upcoming ones regarding the substances you import, and update hazard labels and Safety Data Sheets when changes occur.

Are your products labelled correctly ?

In case of hazardous substances or mixtures you must make sure that the products are labelled and packaged in accordance with the CLP regulation to communicate the risks and ensure safe handling by your customers.

Note that the hazard labels are required to be written in the official language of the EU Member States where the substance or mixture is marketed.

This means that if you wish to sell your products in every European country, the hazard labels must be written in all 24 official languages.

Example of a CLP hazard label:

Can you provide us with EU Safety Data Sheets?

You must provide the relevant information in a Safety Data Sheet, required by the REACH regulation, to communicate the risks and ensure safe handling by your customers.

The Safety Data Sheets must be available in the respective national languages.

This means that if you wish to sell your products in Europe, the Safety Data Sheets must be written in all 24 official languages. Note that the different languages are not copied translations, they must include information required by the national legislations, for example, on health and safety or disposal of waste.