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REACH

Explanations regarding standard questionnaire - Part I


Regarding question 1

If the supplier is not the Manufacturer/Importer but the distributor of substances requiring registration that are contained in the listed products above, it must be clarified whether the supplier can assume that his upstream Manufacturer/Importer will carry out a pre registration.

If the product is a polymer, the purpose of the question is to find out whether the monomers bound in the polymer or other substances bound in the polymer will be registered by the Manufacturer/Importer. This does not refer to residual monomers in the polymer.

Regarding question 1 and 2

Somewhat more time might be needed to answer this question for preparations, because initially the supplier needs to obtain relevant information from his suppliers up till and including the manufacturer/importer. Answering this question with "yes" is no promise of a registration, as - besides REACH - further factors might exert an influence (e.g. unforeseeable future market situations).

Regarding question 3

Example - Determining the crucial registration deadline for substances decisive for product properties:

A product consists of substances 1, 2 and 3. Substances 1 and 2 are decisive for the product properties; they have registration deadlines of 6, 6 and 11 years due to their production or import volumes. Substance 3 - which is not decisive for the specific use of the product and could be replaced, e.g. a solvent - has a registration deadline of 3.5 years because of higher production or import volumes. In this example, substance 3 is not crucial for the product as it can be replaced without affecting the required product properties. Here, substances 2 and 3 are decisive so that the box "6 years" should be ticked. Box "6 years" should be ticked.

The option "immediate registration" means that there is no pre-registration and the substance will be registered without delay, within 12 months after the entry into force of REACH.


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