Brenntag is a supplier to over 100 000 customers across Europe. To a great extent our customers in the REACH Terminology are “Downstream Users” which during their industrial or professional processes use the substance or the mixture in various ways (process categories). As a responsible Distributor we are highly interested that our products are used in compliance with existing legislation, however the ultimate responsibility for compliance lies with the Downstream User.
For the purpose of helping its customers to achieve their commercial aspirations, Brenntag provides products, solutions and value added services of the highest possible quality and in compliance with respective regulations. To this end, Brenntag dedicates regulatory experts and resources in every region of its European Business Segment.
The last registration deadline for substances manufactured or imported in the EEA at a volume per year of 1 ton to below 100 tons is May 31, 2018. ECHA expects 25.000 to 50.000 substances to be registered by this deadline which makes this registration process a challenge for all stakeholders. As there will be many substances to be registered by only a limited number of registrants the process of data-collection, data-generation and dossier submission process should start early in process. One important element in the initial phase of this process will be the identification of uses and their inclusion in the registration dossier.
How you can facilitate the process
Communication in the supply chain:
- cross-check with your industry association for identified uses
- inform Brenntag about identified uses not covered by your association
- provide new information on hazards or inappropriate Risk Management Measures
- Verify your portfolio of purchased chemicals for registration status
- Use covered: check if your use is covered and your conditions of use match those in ES
- When receiving an extended SDS: apply appropriate measures from SDS (sections 7 and 8 of SDS; Section 2 of ES) to adequately control risk
- Use not covered: contact us, we might help or alternatively select another supplier
How Brenntag can support:
- We shall facilitate the use communication along supply chain
- Brenntag supports finding alternative supplier(s) in case one of your suppliers decides not to register a substance
- In case you need assistance in the decision process whether to do a Downstream User Chemical Safety Assessment, Brenntag may provide support under conditions to be negotiated