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Q What roles and obligations do re-importers have under CLP?
A

According to CLP Article 2(19), a re-importer is considered a downstream user. Re-importers are therefore not obliged to notify to the C&L Inventory or to classify in accordance with Title II of CLP, but may also take over the classification derived in accordance with Title II already by another actor in the supply chain. In any case the re-importer has to ensure that the labelling and packaging is in accordance with CLP.

Note that for a re-importer to be considered a downstream user certain conditions have to be fulfilled. First, the re-imported substance must have been registered before it was exported from the EU. In addition, the substance must have been re-imported within the same supply chain. Third, a re-importer needs to be able to show that the re-imported substance is the same as the one that was originally exported. Finally, the re-importer must also be able to show that he has been provided with the respective information in accordance with REACH Article 31 or 32.

When any of the conditions mentioned above is not fulfilled, the re-importer is considered an importer. This means that he has the obligation to classify these substances or mixtures and to notify relevant substance information to the C&L Inventory.

Modified Date: 08/08/2019
Topic: CLP
Scope: Industry roles under CLP
ID: 0168
Version: 1.1
This answer has been agreed with national helpdesks.

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