Identify your obligations
Identify your obligations
Under REACH you can have specific obligations for each individual substance you manufacture, import or use. Your obligations depend on your role in the supply chain for the specific substance.
Even for mixtures or articles, most of the REACH obligations relate to the substances that are contained in them.
If your substance or mixture is classified as hazardous, you will also need to comply with CLP provisions.
What is the Navigator?
The Navigator is an interactive tool that can help you to:
- Clarify your role in the supply chain.
- Identify your obligations for individual substances.
- Find relevant guidance documents, manuals, legislation and links to other information sources that can help you to fulfil your obligations.
A Navigator session applies to a specific substance.
If you formulate, use or deal with mixtures, the first step before using the Navigator is to identify the substances that are contained in those mixtures.
If you are a producer, importer or supplier of articles and you have doubts regarding for which substances you need to use the Navigator, you can start with the link to "Information for producer, importer or supplier of articles" below.
The Navigator will provide a list of obligations for a given substance, based on your answers to a series of questions, e.g. whether you manufacture or import the substance, at what tonnage, for what use, whether the substance is classified as hazardous, etc. During the navigator session for each of these questions there is explanatory text that enables you to select an answer from the options offered.
The tool will guide you step-by-step and help you to determine possible obligations under REACH and CLP for your specific substance and provide relevant support to meet these obligations. However, the Navigator only provides generic advice and does not solve specific problems (e.g. it will not provide recommendations on how a particular substance should be classified under CLP).
- How to use the Navigator?
- What do I need before starting a session?
- What features allow the customisation of the tool?
- How can I retrieve a previous session?
The Navigator will ask you a series of questions concerning your substance. It is important that you answer them correctly. Otherwise the Navigator will give you an incorrect list of obligations. Therefore, it is highly recommended to read the explanations below each question carefully before answering the questions.
In some problematic cases it might be difficult to answer a question. If the guidance is, in this case, insufficient, it is advisable to consult an expert.
The sequence of questions depends on the answers to the previous questions.
A Navigator session is not always the same for all substances: you will only be asked the relevant questions for each case, based on the answers you give at each step.
Before using the Navigator, identify all the substances you are handling, or a selection of substances for which you want to have a Navigator session. You need to use the Navigator for each substance separately as the questions might differ from substance to substance (REACH applies to all substances, whether on their own, in a mixture or in an article).
It might be that you manufacture, import or use several substances in the same way so that your answers to the questions will be similar. In this case, if you run different sessions of the Navigator you will get the same list of obligations for these substances.
- My Comments
You can include your own comments for each question. These are only for your reference (e.g. rationale for choosing the answer, comments to a colleague) and are not taken into account by the tool to determine the user's obligations.
Click on "My comments" button to add a comment. These comments will be saved in the "History" of your session.
A "History" button allows you to display all the questions that have been asked, your answers to them, your comments for each of the questions and the obligations that are foreseen for that situation under REACH and CLP.
It is possible to show only one or several of these topics and to view them either in a table or as a list.
Please note that the session is not over until you answer all the questions. The "History" for the unfinished session will be displayed on the screen under the heading "Temporary History".
The History will be saved for 30 days, including the details from the unfinished session. If you want to save the content of the session for longer, it is possible to do so using the browser functions (e.g. "file, save as …" or equivalent function, depending on internet browser software).
- Modifying the answer to a question
It is possible to go back to change the reply to a question already answered with the "previous" button. It is also possible to change the answer to any other previous question. For that you first need to look at your "History".
In the History, at the end of each question you can click on the "Edit" button. You are then directed to the question, and can modify your answer. If you change the answer to any previous question, your session will continue from that point and all the answers you have given before to subsequent questions will be lost.
- Outcome of a session
At the end of the session, you can find the list of obligations which apply to you, by clicking on the "obligation" button or by checking the "History". From this list of obligations, there will be links to the relevant legislation and guidance documents where more details can be found. Useful links to further information are also provided.
Each time you start a Navigator session you are assigned a unique Navigator ID which is composed of numbers, generated in a random way. If you interrupt a session you can always retrieve it by clicking on "retrieve a previous session" and entering your Navigator ID. "Retrieve previous session" can also be used to retrieve completed sessions.
You are advised to store the Navigator ID for each session as soon as you start a session and to link it to the identity of the substance for which you run the session. Please note that only the session number (and not the substance name either on its own or in combination with the number) can be used to retrieve a previous session.
Once assigned, the Navigator ID number appears at the top of each page of your session after the words "Your Navigator ID is:". Also, if you print the "History" or save it (using your browser function, as discussed above under "History") you can retrieve this number.