As an importer you have a responsibility to advise your customers on how to use your chemicals safely.
The main way to do this is depends on whether you import substances, mixtures or articles.
If you import substances, you have the same obligations as a manufacturer and may need to provide information through an extended safety data sheet (eSDS). For more information, see the manufacturers’ page on supply chain communication responsibilities.
If you import a mixture, the first thing to consider is classification. If you classify your mixture as hazardous, this triggers a requirement to provide a safety data sheet (SDS) as well as specific labelling and packaging requirements. Be aware that if you import a mixture that includes substances that have not previously been registered, then you need to register them.
If you import articles containing substances of very high concern above certain concentrations, you must provide sufficient information to your customers to allow safe use of the product. This is required as soon as the substances are added to the Candidate List. You must also notify ECHA in specific cases (described in the “Notification of substances in articles” page.
Communication up the supply chain
Your customers have the right and in some cases the obligation to communicate information back up the supply chain. They have the right to make a use known upstream to their supplier, with the aim that this use may eventually be covered by the registration. This communication may also be done through the sector organisations by way of a sector use map.
Your customers also have the obligation to communicate upstream any new information on hazardous properties, regardless of the uses concerned, and any other information that might call into question the appropriateness of the risk management measures identified in a safety data sheet supplied to them. For this reason, as an importer, you should have mechanisms in place to facilitate this upstream communication.
Safety data sheets