Practical sheet | REF: FIC0141 V1

Diversifying your suppliers: determining who is responsible for marketing under REACh

Author: Gautier VINCENT

Publication date: July 10, 2011, Review date: October 4, 2016 | Lire en français

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    1. What are the consequences if several suppliers provide the same substance?

    By diversifying your range of suppliers, you can diversify your status under the REACh regulations. In some cases, you may be a downstream user, and therefore not subject to the obligation to register your substance, while in other cases you may be an importer, and therefore subject to the obligation to register your substance.

    In addition :

    • if you are a downstream user, you may find that some EEE suppliers cover your uses in their registration files, while others do not;

    • if you are an importer, you can exceed the import tonne for a substance by taking into account all your imports. This threshold triggers marketing obligations.

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    What are the consequences if several suppliers provide the same substance?