REACH Compliance FAQs





i. Useful links for finding REACH related information

ECHA
ECHA Q & As Support
CEFIC
ETAD

ii. What is REACH Regulation?

REACH stands for the Regulation for Registration, Evaluation, Authorisation and Restriction of Chemicals. The REACH Regulation entered into force on 1 June 2007 to streamline and improve the former legislative framework for chemicals of the European Union (EU), REGULATION (EC) No 1907/2006 (REACH). REACH also created the European Chemicals Agency (ECHA) which has a central co-ordination and implementation role in the overall process. ECHA is located in Helsinki, Finland and manages the registration, evaluation, authorisation and restriction processes for chemical substances to ensure consistency across the countries in which REACH applies.

iii. What is ECHA?

The European Chemicals Agency (ECHA) is the driving force among regulatory authorities in implementing the EU’s groundbreaking chemicals legislation for the benefit of human health and the environment as well as for innovation and competitiveness. https://echa.europa.eu

iv. CLP Regulation

The Classification, Labelling and Packaging (CLP) Regulation ((EC) No 1272/2008) is based on the United Nations’ Globally Harmonised System (GHS) and its purpose is to ensure a high level of protection of health and the environment, as well as the free movement of substances, mixtures and articles.

v. Only Representative

Companies based outside the EEA can appoint a European-based only representative to take over the tasks and responsibilities of importers for complying with REACH. This can simplify access to the EEA market for their products, secure the supply and reduce the responsibilities for importers.

Only representatives have to be:

  • A natural person or legal entity established physically in the EEA
  • Equipped with sufficient knowledge in the practical handling of the substances and information related to them
  • Appointed by a mutual agreement with a manufacturer, formulator or article producer, established outside the EEA
  • Responsible for complying with the legal requirements for importers under REACH

Sudarshan Chemical Industries Limited (A non-EU manufacturer) has appointed Sudarshan Europe B.V. as Only Representative under REACH.

vi. Downstream Users

Downstream users are users of chemicals under REACH and CLP. They are companies or individuals:

  • within the European Union/European Economic Area,
  • who use a substance, either on its own or in a mixture,
  • in their industrial or professional activities.

Examples include:

  • Formulators: produce mixtures, which are usually supplied further downstream. For example, paints, adhesives and cleaning agents.
  • End users: use substances or mixtures but do not supply them further downstream. Examples include users of adhesives, coatings and inks, lubricants, cleaning agents, solvents and chemical reagents like bleaching products.

This includes producers of articles.

  • Producers of articles: incorporate substances or mixtures into or onto materials to form an article. Examples include textiles, industrial equipment, household appliances and vehicles (both components and finished goods).
  • Re-fillers: transfer substances or mixtures from one container to another, generally in the course of repackaging or rebranding.
  • Re-importers: import a substance, on its own or in a mixture, which has originally been produced in the EU, and registered by someone in the same supply chain.
  • Importer with an “only representative”: importers are downstream users when their non-Community supplier has nominated an “only representative” for the purpose of acting as a registrant established in the Community.

vii. General Uses covered by our REACH registrations

  • Colouring agent for paints, plastics and inks
  • Generally, the substance is used in industrial and/or professional settings
  • The substance is contained in consumer products
  • The substance is contained in articles handled by consumers

For any specific query related to uses, please contact us

Contact:

Mr. H M Thombare
Regulator Affairs Department
Sudarshan Chemical Industries Ltd.
regulatory@sudarshan.com


viii. Indirect imports into EU/EEA of our pigments – How does Sudarshan support non-EU customers to fulfil their REACH obligations?

The products purchased from Sudarshan outside the EU and subsequently imported into the EU (i.e., indirect imports) in the form of formulations (for example: masterbatches, coatings, inks, etc) will be accounted for in Sudarshan’s substance registrations.

Customer’s tonnages to EU/EEA are covered by Sudarshan’s registrations. Please contact us regulatory@sudarshan.com to know further.

ix. Does REACH require any changes in Safety Data Sheets?

Yes, according to Articles 31 and 32 of the REACH Regulation some changes in the Safety Data Sheet (SDS) are required. However, the duties and responsibilities for Safety Data Sheets (SDSs) remain largely the same. Guidance for the compilation of Safety Data Sheets is given in Annex II of the REACH Regulation.

x. Substances of Very High Concern (SVHC)

Sudarshan’s product(s) do not contain any Substances of Very High Concern (SVHC) identified on the present ECHA candidate list (https://echa.europa.eu/candidate-list-table). Sudarshan Chemical Industries is monitoring the list of SVHC as published by the European Chemicals Agency (ECHA) on regular intervals.

xi. Exemption under REACH

We are also using natural substances which are exempted from registration according to Article 2 (7) (a) & (b) of REACH.