REACH-roles

REACH designates the following roles in connexion with a substance: Manufacturer - Importer - Trader - Downstream User - Formulator - Consumer.

Pre-registration

We will pre-register all metals and other substances used in quantities of 1 ton or more per year so as to qualify for the above mentioned transition periods as required. Therefore we will work with our suppliers to clear the registration requirements at the same time incorporating the identification of our uses as well as the uses of our downstream customers.

 

Registration

The duty of registration is incumbent on the manufacturer of the substance, or the importer if the manufacture happens outside the EU 27 and an import exists.

In most cases we are in the position of downstream user in the value chain and therefore we will contact our suppliers with information on our uses as well as the uses of our customers.

For some metals we are an importer too. In these cases we will apply for a registration subject to the given terms. We are keen to catalogue our uses as well as the relevant uses of our customers in the registration dossier. To comply with this ambitious challenge, we are involved with different consortia for aluminium, magnesium and others.