New REACH En-Force 3 is waiting in the wings

The joint projects of the market surveillance for REACH and CLP regulation, REACH-En-force 1 and 2 have already passed.

As the focus of REACH En-force 1 was the creation of awareness for this new legislation, only few offences have been reported by member states. The second project focused on so called Downstream Users and the new REACH Safety Data Sheet. Many gaps were detected, mostly in Safety Data Sheets and within the communication in the supply chain. Whilst the results of the En-force 2 project are expected for autumn this year, the next En-Force project is already waiting in the wings.

REACH En-force 3 will focus on substances and mixtures that will be exported to the European Union. Therefore, a pilot project in cooperation with the customs is carried out in south Germany (Baden-Württemberg).

First results of the pilot project show that some importers of substances rely on information about their substances being registered by a so called Only Representative without even having any further contact details or registration numbers.

In other cases, the purchase department is not aware about the registration obligations that may arise from purchasing outside the European Union.

If you are importer of substances, be sure on the compliance of the substances you are importing. K&L helps you in demanding information that you should be able to present when authorities are knocking on your door.