Manufacturers and Importers of Polymers

Any company or person established in the EEA that uses a substance or mixture during industrial or professional activities may be considered to be a downstream user under REACH legislation. Hence, many companies operating in the polymer industry will be deemed to be downstream users even if they are also manufacturers and/or importers of materials. The only exceptions would be chemical traders that are providing only distribution functions. 

It is the responsibility of every downstream user to ensure that it is taking the necessary actions to ensure chemical safety. A key part of this process is making sure that risk 

Each registration dossier must reference specific indentified uses of the substance [which includes its use in mixtures (and even articles)]. To help enable this process, downstream users have certain rights to enable their use of a substance (whether on its own or in a supply chain) to be communicated through the supply chain. 

A company in a supply chain is required to pass on information relating to use that it receives to help this information reach the original manufacturer or importer. Alternatively, a company can establish its own internal system to ensure that it can cover use adequately. 

Information relating to supply chain communications are examined in Chapter 6. 

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The obligations of manufacturers and importers of polymers are listed next ... 

Manufacturers and importers of polymers do not have to register individual polymers. They are not required to provide to the agency any information related to the intrinsic properties of the polymer itself with the exception of classification and labelling (if applicable) (see Chapter 6). Article 2 9. 

Manufacturers and importers of polymers are required to submit a registration for the monomer substance(s) or any other substance chemically bound to the polymer except if these have already been registered by the supplier or another actor in their supply chain. Article 6 3. 

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